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Technical Interpretation - External
30 March 1994 External T.I. 9330105 - LIFE ESTATES & REMAINDER INTERESTS IN REAL PROPERTY
30 March 1994 External T.I. 9330105- LIFE ESTATES & REMAINDER INTERESTS IN REAL PROPERTY Unedited CRA Tags 43.1 70(5) 70(6) 70(9) 73(3) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... A's will a Life Estate in farmland is conveyed to his spouse & the Remainder Interest to the children. ... Subsections 70(6), 70(6.2) & 70(5) may apply depending on the facts. ...
Administrative Letter
23 March 1994 Administrative Letter 9332416 F - Japan Inhabitant's Tax — Income or Profits Tax
23 March 1994 Administrative Letter 9332416 F- Japan Inhabitant's Tax — Income or Profits Tax Unedited CRA Tags 126(7) non-business income tax, IT-270R2 PRINCIPAL ISSUES: Japanese "Inhabitant's Tax" — Is it an "Income or Profits Tax"? ... Licardo 933241 XXXXXXXXXX This is in reply to your memorandum dated January 5, 1994, in which you asked for our comments concerning whether the Japanese "Inhabitant's Tax" would be considered an "income or profits tax" for purposes of paragraph 126(7)(c) of the Income Tax Act ("Act"). ...
Miscellaneous severed letter
15 May 1992 Income Tax Severed Letter 9212785 - Taxation of Indians — situs of payor
15 May 1992 Income Tax Severed Letter 9212785- Taxation of Indians — situs of payor Unedited CRA Tags 81(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... All books & records are located there. All payroll is handled through there, the main signing authorities are situated there and the executive is there XXX. ... In determining where the situs or origin of a business is one should consider the following factors: • the location of the business office- where the books and records are kept- where transactions with clients and or suppliers are arranged- where employees report for work or are paid from- where inventory or stock supplies are ordered and maintained While the XXX is not in fact a corporation, we can draw an analogy between this determination and the cases that establish criteria to determine the residence of a corporation. ...
Miscellaneous severed letter
10 May 1990 Income Tax Severed Letter RRRR260 F - Demande d'opinion — corporation à objet unique
10 May 1990 Income Tax Severed Letter RRRR260 F- Demande d'opinion — corporation à objet unique Unedited CRA Tags none A l'attention de 5-9304A. ... Monsieur X souscrit 100 000 $ dans sa corporation, laquelle utilise le produit de souscription pour acquérir un avion de 100 000 $. 4. ...
Miscellaneous severed letter
18 November 1999 Income Tax Severed Letter 9928215 - Interpretation Bulletin IT-99R5 — legal fees, child support
18 November 1999 Income Tax Severed Letter 9928215- Interpretation Bulletin IT-99R5 — legal fees, child support SUMMARY: Interpretation Bulletin IT-99R5- legal fees, child support—ITA-18(1)(a)—Whether Interpretation Bulletin IT-99R5 “Legal and Accounting Fees” will be revised to reflect Technical Interpretation number 9828805 dated March 31, 1999. ...
Miscellaneous severed letter
7 October 1990 Income Tax Severed Letter - Capital cost allowance — mobile homes
7 October 1990 Income Tax Severed Letter- Capital cost allowance — mobile homes Unedited CRA Tags Reg. ...
Miscellaneous severed letter
31 October 1989 Income Tax Severed Letter ACF3316 - SR & ED Expenditures
31 October 1989 Income Tax Severed Letter ACF3316- SR & ED Expenditures October 31, 1989 Mr. ...
Miscellaneous severed letter
26 September 1989 Income Tax Severed Letter ACC8687 - Subaru Auto Canada Ltd. v. The Queen (1982 & 1981)
The Queen (1982 & 1981) E.E. Campbell 19(1) 613-957-2067 September 26, 1989 19(1) Re: Subaru Auto Canada Ltd. v. ...
Miscellaneous severed letter
29 July 1988 Income Tax Severed Letter 5-6084 - []
29 July 1988 Income Tax Severed Letter 5-6084- [] Unedited CRA Tags Reg. 6208 Dear Sirs: This is in reply to your May 25, 1988 letter concerning paragraph (c) of proposed section 6208 of the Income Tax Regulations. ...
Miscellaneous severed letter
9 December 1983 Income Tax Severed Letter 5-5521 - []
9 December 1983 Income Tax Severed Letter 5-5521- [] Unedited CRA Tags 95(2)(i) XXX This is in reply to your letter of September 23, 1963 with respect to the application of paragraph 95(2)(i) of the Income Tax Act (the Act). ...