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May 17, 2002 Audit Directorate HEADQUARTERS Anne Wilson Wayne Antle, CGA Manager (613) 957-2102 Technical Applications & Valuations Division 2002-013954 Transfer of Professional Income to a Corporation This is further to your email of May 8, 2002, concerning our decision not to revise our position on the transfer of professional income to a professional corporation, despite the decision of the Tax Court in the case of Jerome Wallsten and Lakeside Properties Ltd. v. ...

& 2.) In our document 9619803 dated XXXXXXXXXX, 1996, which the taxpayer's representative has referred to, we provided rulings in respect of a supplemental retirement arrangement ("SRA") that was similar in design to the plan in question here. ...

July 8, 2002 XXXXXXXXXX Income Tax Rulings Verification & Enforcement Division Directorate XXXXXXXXXX Bob Naufal (613) 957-2744 2002-014164 XXXXXXXXXX This is in response to your memo dated May 14, 2002, wherein you requested our comments as to whether Pre-1994 Section 79 ("Former Section 79") or Section 80 ("Former Section 80") would apply to the above-mentioned Taxpayer. ...

MAIL TYPE: CCRA Documents; (Forms & Guides, Internal Queries, Appeals Referrals) Principal Issues: Can the estate claim a subsection 146(8.9) deduction on the final 146(1) return in respect of RRSP amounts still unclaimed by the beneficiary? ...

February 27, 2003 Individual Returns and Headquarters Payments Processing Directorate Income Tax Rulings Pensions & Trusts Section Directorate G. ...

Troy of the North York Tax Services Office (file # 962478) concerning the same issue, such response will be amended to reflect our position described above. ...

Principal Issues: In the definition of "permanent establishment" in paragraph 400(2)(a) of the Income Tax Regulations, do the words " a fixed place of business" mean a fixed place of business in Canada? ...

., Verification & Enforcement Division M.P. Sarazin (613) 824-5441 Attention: Naomi Tsuji 2000-003500 Salary Deferral Arrangement We are writing to you in response to John Gordon's memorandum of June 27, 2000, wherein he requested our views as to whether a specific employee incentive plan would constitute a salary deferral arrangement for purposes of the Income Tax Act (the "Act"). ...

August 28, 2000 XXXXXXXXXX Tax Services Office HEADQUARTERS Verification & Enforcement Division S. ...

Jim Wilson Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch- 4-... ...