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Principal Issues: Additional Ruling Position: OK Reasons: 111(1)(A) XXXXXXXXXX 993189 Attention: XXXXXXXXXX XXXXXXXXXX 1999 Dear Sirs: Re: Advance Income Tax Ruling XXXXXXXXXX This is in response to our telephone discussion (XXXXXXXXXX) on XXXXXXXXXX, concerning the above-noted advance income tax ruling (file # 991140) wherein you requested an additional ruling on the application of section 111 of the Act and an amendment to the ruling in respect of subsection 245(2) of the Act on behalf of the above-noted taxpayers. ...

XXXXXXXXXX XXXXXXXXXX 1-992400 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1999 Dear Sirs: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Ruling # 992051 (the "Ruling") This is in reply to your facsimile dated XXXXXXXXXX in which you requested an amendment to the Ruling issued to the above-referenced taxpayers on XXXXXXXXXX, 1999. ...

As a result of your letter, the words "investment in a limited partnership " on line 2 of Paragraph 6 of the Ruling will be deleted. ...

XXXXXXXXXX 2000-004448 Attention: XXXXXXXXXX XXXXXXXXXX, 2000 Dear Sirs Re: Advance Income Tax Ruling XXXXXXXXXX- Ruling # 2000-003842 This is in reply to your facsimile dated XXXXXXXXXX in which you requested amendments to the Ruling issued to the above-referenced taxpayer on XXXXXXXXXX, 2000 (the "Ruling"). ...

Reasons: XXXXXXXXXX XXXXXXXXXX 1-990115 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1999 Dear Sirs: Re: XXXXXXXXXX Advance Income Tax Ruling # 982495 (the “Ruling Letter”) This is in reply to your facsimile of XXXXXXXXXX in which you advised that on XXXXXXXXXX purchased for cancellation a portion of the shares owned by the Trust and did not redeem such shares as described in paragraph 13 of the Ruling Letter. ...

XXXXXXXXXX 2018-076670 XXXXXXXXXX, 2018 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – supplement to file 2017-070621 XXXXXXXXXX We are writing in response to your letter of XXXXXXXXXX wherein you advised us of certain changes to the facts in the advance income tax ruling 2017-070621 issued on XXXXXXXXXX (the “Original Ruling”) on behalf of the above-referenced taxpayers. ...

The Department, however, has not accepted this position (see paragraphs 5 & 7 of IT-505). ...

15 May 1990 Ruling 90065001 F- Time Limit for Assessment Unedited CRA Tags n/a Minister's Office 90065001 Central Records Returned to Technical Review Section, Publications Division Room 1016, Cumberland Place   May 15, 1990 19(1) I am writing in response to your letter of February 23, 1990, concerning the tax affairs of your client, 19(1).  ...

DEPARTMENT'S POSITION Subject to certain adjustments set out therein, paragraph 89(1)(c) of the Act provides that the "paid-up capital" in respect of a class of shares of the capital stock of a corporation is "... an amount equal to the paid-up capital in respect of the class of shares at the particular time, computed without reference to the provisions of this Act... ...

Campbell    (613) 957-2067 September 14, 1989 Re:  Article 23, Canada-Sweden Income Tax Convention In our letter of July 11, 1989 we indicated to you that we had written to the Swedish competent authority to request its views on the situation which you had outlined in your letter to us of March 9, 1989.  ...