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10 May 1990 Income Tax Severed Letter RRRR443- Interest deductibility — newly incorporated branch Unedited CRA Tags 20(1)(c) xxxxx 5-9052 Peter Lee (613) 957-2745 Attention: xxxxx May 10, 1990 Dear Sirs: Re: Interest Deductibility- Newly Incorporated Branch Operation This is in reply to your letters of November 7, 1989 and March 1, 1990. ...

7 November 1990 Income Tax Severed Letter- Deceased taxpayer — election under subsection 70(6.2); also whether section 54.2 applies to a partnership Unedited CRA Tags 70(6), 70(6.2), 54.2 QUESTION I-100 DECEASED TAXPAYER-ELECTION UNDER SUBSECTION 70(6.2) Subsection 70(6.2) provides that the legal representative of a deceased taxpayer may elect that the provisions of subsection 70(6) do not apply on the death of a taxpayer with respect to any property specified in the election (i.e., you can elect to have the transaction take place at fair market value rather than at tax values). ...

7 October 1991 Income Tax Severed Letter- Canadian controlled private corporation — ownership by a trust Unedited CRA Tags 125(7), 256(5.1) CCPC Status- Ownership by a Trust Question 50 Assume all of the common shares of a private corporation which is incorporated and carries on business in Canada are owned by a trust. ...

4 February 1981 Income Tax Severed Letter RRRR34- Canada-Australia treaty — treatment of capital gains and dividends Unedited CRA Tags 2(3), 115(1)(b), 84, 212.1, Canada–Australia Income Tax Convention Dear XXX This is in reply to your letter of December 29 concerning the Canada-Australia Income Tax Convention (1980) (the Convention) which has yet to be ratified. ...

7 December 1991 Income Tax Severed Letter- Scientific research and experimental development — eligibility of landscaping costs Unedited CRA Tags 37, 20(1)(aa) Dear Sirs: Re: Scientific Research and Experimental Development-Landscaping Costs This is in reply to your letter of July 5, 1991 concerning subsection 37(1) of the Income Tax Act (the "Act"). ...

7 July 1991 Income Tax Severed Letter- Recovery of underdeducted non-resident tax — non-resident reinsurer Unedited CRA Tags 212(1)(b), 212(11) Subject: XXX This is in reply to your letter of April 10, 1991 concerning the review by the Non-Resident Unit in the Vancouver District Office of the XXX and the potential recovery of underdeducted non-resident tax. ...

7 May 1990 Income Tax Severed Letter RRRR394- Butterfly — allocation of liabilities Unedited CRA Tags 55(3)(b) Butterfly- Allocation of Liabilities Question Would the Department please provide its latest guidelines on the allocation of liabilities for purposes of a net equity method butterfly transaction. ...

7 December 1991 Income Tax Severed Letter- Foreign exchange — income or capital Unedited CRA Tags none XXX Principal issues Paragraph 1 of IT-95R outlines the major issue which must be addressed, that being, whether foreign exchange gains or losses are income or capital in nature. ...

10 December 1992 Income Tax Severed Letter 9212185- SR & ED Universities Approved Research Institute Unedited CRA Tags 37(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. ...

19 December 1985 Income Tax Severed Letter 5-8032- [] Unedited CRA Tags 67, 69, 212(1)(a), 212(3), 212(4) XXXX A.A. ...