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17 February 1988 Income Tax Severed Letter 5-4070- [] XXXX Peter K. Noack (613)957-8963 February 17, 1988 Dear Sirs: We reply to your letter of October 8 concerning certain incentive programs involving various bonuses that would be added by issuers of RRSPs to the assets of newly opened plans or plans to which new contributions are made. ...

11 August 1989 Income Tax Severed Letter ACC8387- Form T85- Deduction of SR & ED Tax Credit by Trusts and Partnerships FORM T85 This is in reply to Mr. ...

26 January 1988 Income Tax Severed Letter 5-5241- [] Peter. K. Noack (613)957-8963 January 26, 1988 Dear Sirs: We reply to your letter of December 14 concerning the transfer of an annuity contract under an unmatured RRSP by the issuer on behalf of the annuitant to the annuitant's self-directed RRSP of another issuer. ...

8 June 1988 Income Tax Severed Letter 5-5981- [] XXXX W.C. Harding (163)957-3499 June 8, 1988 Dear Sirs: Re: 1988 RRSP Contribution Limits This is in reply to your letter of April 27, 1988 wherein you requested our confirmation that in accordance with the provisions of subsection 146(5) of the Income Tax Act (the Act), as presently written, an employee who is a member of a deferred profit sharing plan (DPSP) in 1988 may contribute up to the lesser of $7,500 and 20% of his earned income for the year to an RRSP, if his employer does not contribute to the DPSP in the year but will make a contribution to the DPSP in 1989 in respect of the year. ...

7 March 1991 Income Tax Severed Letter- Medical expenses — electrolysis treatments Unedited CRA Tags 118.2(2), 118.4(2) Subject: Medical Expenses In your memorandum of February 6, 1991, you have referred to a situation where a taxpayer claimed electrolysis treatments as an eligible expense under subsection 118.2(2) of the Income Tax Act (the Act) for the purposes of the medical expense tax credit. ...

2002 Ruling 2002-0167263- CHANGES TO TERMS OF DEBT & CONSEQUENCES Unedited CRA Tags 212(1)(b)(vii) 20(1)(f) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... (b) Whether the cash amount paid in satisfaction of the XXXXXXXXXX % Interest is deductible under paragraph 20(1)(f)? ... (k) The Fair Market Value of the XXXXXXXXXX% Interest may be determined by an investment banker of a national standing in Canada experienced in XXXXXXXXXX businesses; Note that the XXXXXXXXXX % interest is also payable upon the redemption of the Debentures because of the definition of "Redemption Amount" (see definition above) which refers to the XXXXXXXXXX % interest. ...

12 June 2007 Internal T.I. 2007-0236641I7- Deductibility- ETA interest & penalties Unedited CRA Tags 18(1)(t) 67.6 9 7309 Principal Issues: 1. ... June 12, 2007 Owen Newell, CGA HEADQUARTERS Manager Income Tax Rulings General Operations Unit Directorate Excise & GST/HST Rulings Directorate Tim Fitzgerald, CGA 2007-023664 Deductibility of interest and penalties imposed under Part IX of the Excise Tax Act We are replying to your email of May 17, 2007 wherein you have asked for our views regarding the deductibility of interest and penalties imposed under the Excise Tax Act (the "ETA") for the purpose of computing income for tax purposes. ... Renée Shields Section Manager Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

29 August 2006 Internal T.I. 2006-0193111I7- vesting indefeasibly & validity of trust documents Unedited CRA Tags 70(6) Principal Issues: Did shares vest indefeasibly with the surviving spouse with 36 months of death? ... Despite the apparent irregularities in the director's resolution concerning who requested the redemption, we understand that it was the XXXXXXXXXX % of the shares held by the estate for the children and testamentary debts that were redeemed and not the shares that were transferred to the trust for the benefit of the Spouse. ... Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

9 May 1996 Internal T.I. 9608597- PRIOR PERIOD ALIMONY & WORDING OF AGREEMENT Unedited CRA Tags 60(b) 60.1(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. ... Principal Issues: prior period maintenance payments & phraseology required in the agreement or other document Position: agreement must specify that the prior period payments are made pursuant to the agreement but there is no specific wording required Reasons: it is 60.1(2) that requires a reference to the specific provision of the Act May 9, 1996 SURREY TAX CENTRE Headquarters M. ... Humenuk Assistant Director 957-8953 Enquiries & Adjustments Attention: Carla Fraser Client Services Section 960859 Prior Year Maintenance Payments We are replying to your memorandum of February 27, 1996 concerning the type of wording required in a written agreement, decree, order or judgement of a competent tribunal in order for a taxpayer to deduct payments made to his or her spouse or former spouse prior to the date of the agreement, decree, order or judgement. ...

24 October 1995 External T.I. 9522905- HEALTH SPENDING ACCT WITH VARYING PLAN YRS & AMT OF CR Unedited CRA Tags 6(1)(a) 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. ... Principal Issues: 1) health spending account & whether the plan year can vary according to employee 2) can the plan use the health care spending account to adjust for changes in flex credits allocated by salary or for changes in cost of benefits-other issues include c/f of credits at year end, changes for life events Position: 1) yes, the plan year for each employee can begin with the employee's month of birth 2) no the amount of flex credits must be fixed at beginning of year & cannot be reallocated except in the event of a life event (although some portion of the fixed amount of credits allocated prior to the start of the plan yr may have been calculated with reference to the employee's salary at that time Reasons: if the credits can be transferred between options or if the amount of credits is not fixed, the credits may be seen as additional remuneration or the flex plan may be considered an employee benefit plan A. ...