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19 April 1991 External T.I. 9105075A F- Canada-France Tax Convention- France Pension Plan Unedited CRA Tags 6(1)(a)   5-910507 Dear Sirs: Re:  Our letter of April 4, 1991 Further to the above-noted letter and our telephone conversation of April 15, 1991, this is to advise that Article 29 of the Canada-France Tax Convention (1975) contains a provision which may be applicable to the situation on which you asked us to comment. ...

In our view, "... debt obligations in respect of a borrowing..." as used in subparagraph 20(1)(e)(v) refers to the debt obligations comprising the borrowing first referred to in subparagraph 20(1)(e)(ii). ...

However, we can make the following general comments concerning paragraph 212(1)(c) of the Act which hopefully will be of assistance to you: 1.      ...

Dunn   (613) 957-8961 Attention: 19(1) August 1, 1990 We are writing in response to your correspondence of March 7, 1990 wherein you requested the opinion of the Department regarding certain aspects of a proposed new  24(1)  which your company is currently developing. ...

If, in the situation described above, the trustee and the beneficiaries agree that the spouse should be paid $ 160,000 out of the RRSP proceeds, a designation of that amount for the purposes of subsection 146(8.1) would be reasonable in our view. ...

Finalement, c'est à l'article 43 de la même loi qu'on empêche un médecin d'incorporer sa pratique professionnelle en y mentionnant que "... nul ne peut poser l'un des actes décrits à l'article 31, s'il n'est pas médecin. ...

EACC9655 F- Reverse Mortgage Plan for Homeowners Unedited CRA Tags n/a Minister(2)/DM's Office Central Records Author/Section Chief Return to Rulings Directorate, Room 300, Met.   ...

5 February 1993 External T.I. 9233605 F- Treatment of Pension From the XXXXXXXXXX (4106-6) Unedited CRA Tags 56(1)(a)(i), Treaty US Article XVIII   XXXXXXXXXX  Dear Sirs: RE:  Treatment of Pension from the XXXXXXXXXX This is in reply to your letter of November 2, 1992 wherein you requested clarification as to the tax treatment of pension payments received from the XXXXXXXXXX by a resident of Canada, in view of the wording of Article XVIII (Pensions and Annuities) of the Canada-U.S. ...

10 December 1991 External T.I. 9121305 F- Delisted Shares Public Corporation Eligible Investment Unedited CRA Tags ITR 4900   5-9121305  Dear Sirs: Re:  De-listed shares as investments for an RRSP This is in reply to your letter of June 5, 1991 pertaining to the eligibility of shares as qualified investments for an RRSP after they have been de-listed from a prescribed stock exchange in Canada. ...

17 December 1991 External T.I. 9134075 F- Protest of Cost of Translation of Manitoba Law to French Unedited CRA Tags 3   913407 Dear Madam: Re:    Liability for Income Tax We have received your letters of June 13 and November 29, 1991 concerning the cost of translating the Manitoba legislation into French. ...