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11 January 1990 Ruling 74583 F- Canada Council Project Grants Unedited CRA Tags 56(1)(n), 56(1)(n.1)   January 11, 1990 Current Amendments and Business and General Regulations Division Division B.J. ... Thornley   957-2101 N.M. Sheerin File No. 7-4583 Subject: Canada Council Project Grants This is in reply to your memorandum of December 12, 1989, and further to our telephone conversations concerning your request that we confirm the basis for taxing Canada Council project grants received by artists. ...

21 November 1989 Ruling 89M11593 F- OECD Working Party No 8- New Technologies Unedited CRA Tags n/a   November 21, 1989 Mr. ... Savage   (613) 957-2070 Attention: Mr. W. Szyc A/Director, EDP Audit Applications OECD Working Party No. 8- New Technologies Attached is a complete set of the material that we have received on the topic of New Technologies and Tax Compliance.  ...

30 March 1990 Ruling 74551 F- Corporations associated through a third corporation Unedited CRA Tags 256(2)   March 30, 1990 Audit Programs Directorate Specialty Rulings Audit Applications Division Directorate Technical Publications Section P.W. Osborn   957-2120 R.S. Biscaro Acting Director File No. 7-4551 Subject:  256(2) Election This is in reply to your memorandum of November 28, 1989 which details a hypothetical situation involving four corporations; B, C, D and E, each of which is associated with corporation A but is not otherwise associated with each other.  ...

30 January 1990 Ruling HBW4125N1 F- Canada-Netherlands Income Tax Convention Unedited CRA Tags n/a   January 30, 1990 Ms. ... Wilson Assistance Division 957-2063 Attention:  Monica Jones-Kisil   HBW 4125-N1 Canada-Netherlands Income Tax Convention We are writing in reply to your memorandum dated October 27, 1989, concerning the taxability of pensions received from the Netherlands.  ...

23 April 1990 Ruling 74681 F- IT-92R2 Unedited CRA Tags 9(1), 12(1)(b), 12(2)   April 23, 1990 P. Gamage Head Office Chief of Audit Specialty Rulings Windsor District Office Roberta Albert   (613) 957-2098 Mrs. ...

23 March 1990 Ruling 90M03333 F- Deduction from Tax for Employees of International Organizations Unedited CRA Tags 126(3), 250(1)   March 23, 1990 Mr. ... Campbell International Audits Division   File No. 90M03333 Attention:  Mr. ...

The Taxpayer is a limited partner of Master LP and holds Class A LP Units representing XXXXXXXXXX % of the outstanding units of Master LP. ... Master LP GP is the general partner of Master LP and holds XXXXXXXXXX % general partnership interest in Master LP. ... The Taxpayer has an indirect economic interest in the Properties by virtue of its XXXXXXXXXX % ownership of the shares of Master LP GP, the sole general partner of Master LP, and its XXXXXXXXXX % ownership in the units of Master LP which, in turn, is the sole limited partner of the Sub-Partnership. ...

The Band has passed by-laws under section 81 & 83 of the Indian Act and is performing several functions of government. 2. ... Provided the other requirements of guideline 2 & 3 are met, the status Indians will be exempt from income tax. ... The limited partners of LP2 will be LP1 as to XXXXXXXXXX % and XXXXXXXXXX as to XXXXXXXXXX%. ...

Corp B is XXXXXXXXXX % owned by Corp A and XXXXXXXXXX % owned by Corp F, a non-related company resident in Country 3. 3. ...

Bco indirectly owns XXXXXXXXXX % of Holdco, a corporation that is incorporated and licensed as an International Business Corporation and is resident in XXXXXXXXXX. Holdco owns XXXXXXXXXX % of Subco, a corporation that is incorporated and licensed as an International Business Corporation and is resident in XXXXXXXXXX. ... The other XXXXXXXXXX % of Holdco is indirectly owned by Pubco, a Canadian corporation that is not part of the Eco Group. 7. ...