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26 September 1989 Ruling 89M09623 F- Letter Response Unedited CRA Tags n/a   September 26, 1989 Mr. ... Campbell   957-2067 Attention:  Mr. Bernie Gillis 24(1) Attached is a copy of the letter which was discussed in your telephone conversation. 19(1) called and we advised him to make direct contract with you. ...

11 January 1990 Ruling 90M01493 F- Tax Returns Charged to Technical Interpretations Unedited CRA Tags n/a   January 11, 1990 Sudbury Taxation Center Technical Interpretation Ms. ... Buetow   957-9226 Subject: Tax Returns Charged to Technical Interpretations Division The December 28, 1989 Online Tax Payer Information Systems Work Section Aging Report shows this Division as holding the Permanent Documents for 19(1) All documentation was returned to the Kitchener District office on June 14, 1989 as indicated by the routing slip and memorandum (Appendix A). ...

La mention «Catégorie «C» » au début du sixième paragraphe du numéro 5 est remplacée par «Catégorie «D» ». 3. ...

This is so even though the employee may receive cash for the vested stock options. 2.      ... In this regard, it is your opinion that the merger agreement would not represent "... any term or condition of the share or any agreement in respect of the share... ... Your second opinion involves a determination of whether the merger and its related arrangements constitute "... any term or condition of the share or any agreement in respect of the share... ...

It is estimated that less than XXXXXXXXXX % were owned by non-residents of Canada. 6. ... GP subscribed for one GP Unit for a nominal cash consideration of $XXXXXXXXXX, representing a XXXXXXXXXX % general partnership interest in LP, and the FUND subscribed for XXXXXXXXXX Class A LP Units for a cash consideration of $XXXXXXXXXX, representing a XXXXXXXXXX % limited partnership interest in LP, on formation of LP. ... GP will use these funds to subscribe for additional GP Units of LP in order to maintain the partnership interest of GP in LP at XXXXXXXXXX %. 37. ...

La dernière cession a eu lieu le XXXXXXXXXX à un prix de XXXXXXXXXX $. 10. ... Selon l'article XXXXXXXXXX, SOCIÉTÉ a l'autorité d'adopter des règlements, entre autres fins, « pour le prélèvement du capital, par l'émission d'actions transportables ou autrement ». ... Il résultera de ces transactions que Nouvelle SOCIÉTÉ détiendra 100 % des actions émises de la SOCIÉTÉ. 24. ...

The Band also receives grant funding from "XXXXXXXXXX " revenue grants, upon application, pursuant to a "XXXXXXXXXX ", effective XXXXXXXXXX. ... XXXXXXXXXX Proposed Transaction The Band will purchase, with cash, a $XXXXXXXXXX non-redeemable, guaranteed investment certificate (the "GIC") issued by the XXXXXXXXXX through the branch located at XXXXXXXXXX The GIC will earn interest at a rate of approximately XXXXXXXXXX % compounded annually. ...

Pursuant to § 1(2) of the Investment Funds Act, the Units of Fund B may be held by no more than ten Unitholders, each of whom must be known to the Investment Company and may not be a natural person. 13. ... Fund B is governed by the Investment Funds Act, as confirmed by § 1(1) of the Fund Provisions, which states "The Investment Company shall be subject to the rules of the Austrian Investment Fund Act of 1993". § 2(1) of the Fund Provisions states, "Joint ownership of the assets belonging to the investment fund is divided up into equal joint ownership units." § 2(3) of the Fund Provisions states "every acquirer of a unit certificate shall acquire, in the amount of the joint ownership units vested therein, joint ownership in the total assets of the fund. ...

1 November 1991 Ruling 91M11253 F- Partnership's Gain on Settlement of its Debts Unedited CRA Tags 80(1)(a) QUESTION 21.      ... ANSWER 21.     Section 80 would not apply to the partners of a partnership in respect of any part of the partnership's gain on settlement of its debts.  ...

14 December 1989 Ruling 74373 F- Pension Splitting on Separation Unedited CRA Tags n/a   December 14, 1989 TO: Assessing and Enquiries FROM: Business and General Directorate Division Enquiries and Taxpayer J.D. Jones Assistance Division 957-2104   Mrs. P. McNally Director File No. 7-4373 SUBJECT:  Pension Splitting on Separation This is in reply to your memorandum of September 25, 1989, wherein you requested our opinion on the income tax consequences to a spouse in receipt of pension income pursuant to a written separation agreement.  ...