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7 July 1991 Income Tax Severed Letter- Life expectancy tables — joint and last survivor Unedited CRA Tags Reg. 300(2) Dear Sirs: Re: Life Expectancy Tables- Joint and Last Survivor This is in reply to your correspondence concerning life expectancy tables sent by facsimile transmission July 8, 1991. ...

7 October 1991 Income Tax Severed Letter- Capital gains exemption — prescribed share status on amalgamation Unedited CRA Tags Reg. 6205(4)(c) Capital Gains Exemption- Prescribed Share Status on Amalgamation Assume that preferred shares are issued by Amalco on an amalgamation in exchange for preferred shares of a predecessor corporation. ...

7 November 1991 Income Tax Severed Letter- Qualified small business corporation shares — “Primarily” test Unedited CRA Tags 110.6(1) Qualified Small Business Corporation Shares- "Primarily" Test QUESTION Under the definition of a qualified small business corporation share in 110.6(1) of the Act, one of the requirements is that assets are used in an active business carried on "primarily" in Canada (subparagraph (c)(i) of the definition). ...

7 December 1991 Income Tax Severed Letter- Deferred salary leave plans — eligibility of a teacher to use August at the beginning of, or July at the end of, a semestered leave in qualifying for the six consecutive months criteria Unedited CRA Tags Reg. 6801(a)(i) Dear Sir: Re: Deferred Salary Leave Plans This is in reply to your letter of September 25, 1991, to the Kingston District Office of Revenue Canada Taxation, requesting information on the eligibility of a teacher to use August at the beginning of, or July at the end of, a semestered leave in qualifying for the six consecutive months criteria. ...

20 November 1980 Income Tax Severed Letter RRRR29- Foreign exchange gains and losses — IT-95 Unedited CRA Tags IT-95 This is in reply to your memorandum dated September 11, 1980 concerning suggested changes to IT-95. ...

12 November 1980 Income Tax Severed Letter RRRR28- Section 15(2)(b) of the Teachers' Superannuation Act — non-resident tax exemption Unedited CRA Tags 212(1)(b) Dear Sirs: This is in response to your letter of October 28 concerning a specific section of the XXX Superannuation Act. ...

2 September 1980 Income Tax Severed Letter RRRR19- Certificate of Exemption — NR602A Unedited CRA Tags 212(1)(b)(iv), 212(14) Dear XXX This is in response to your letter of June 2 dealing with a withholding tax exemption by the XXX when purchasing Canadian commercial paper. ...

7 April 1991 Income Tax Severed Letter- Employee profit sharing plan — non-resident employees Unedited CRA Tags none Dear Sirs: Re: Employee Profit Sharing Plan ("EPSP") Non-Resident Employees This is in reply to your letter of March 28, 1991 concerning the above- referenced matter. ...

7 September 1991 Income Tax Severed Letter- Taxable Canadian property — shares in a public corporation Unedited CRA Tags 115 Taxable Canadian Property- Shares in a Public Corporation Question Subparagraph 115(1)(b)(iv) defines taxable Canadian property to include a share of the capital stock of a public corporation if at any time during the prescribed five-year period not less than 25% of the issued shares of any class belonged to the non-resident person, non-arm's length persons or a combination of the foregoing. ...

7 November 1990 Income Tax Severed Letter- Acquisition of control — recognition of unrealized foreign exchange gains and losses Unedited CRA Tags 111(4), 248(1) QUESTION I 88 Acquisition of Control- Recognition of Unrealized Foreign Exchange Gains and Losses Control of a corporation is acquired at a time when it has an unrealized capital loss on preferred shares of a foreign affiliate. ...