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Client Assistance Directorate T1 Returns & Guides Division ...

REASONS FOR POSITION TAKEN: Previous position and consistent with the ordinary meaning.   932878 XXXXXXXXXX B. ...

The applicable rates for 1993 were as follows: Taxable Income Tax $29,590 or less 17% $29,590 $ 5,030 plus 26% on next $29,590 $59,180 or more $12,724 plus 29% on remainder To the federal tax must be added provincial or territorial taxes. ...

Subsection 5(1) of the Act states that, "..., a taxpayer's income for a taxation year from an office or employment is the salary, wages and other remuneration, including gratuities, received by him in the year. ...

The retirement savings plan in these cases is an arrangement under which an individual makes a payment "as a deposit with a branch or office in Canada of a person who is, or is eligible to become, a member of the Canadian Payments Association or a credit union that is a shareholder or member of a body corporate referred to as a "central" for purposes of the Canadian Payments Association Act ". ...

The retirement savings plan in these cases is an arrangement under which an individual makes a payment "as a deposit with a branch or office in Canada of a person who is, or is eligible to become, a member of the Canadian Payments Association or a credit union that is a shareholder or member of a body corporate referred to as a "central" for purposes of the Canadian Payments Association Act ". ...

Patricia Spice XXXXXXXXXX 942064 Attention: XXXXXXXXXX August 25, 1994 Dear Sirs: Re: Deduction for a Refund of an Undeducted Premium Pursuant to subsection 146(8.2) of the Income Tax Act (the "Act") This is in reply to your facsimile transmission of August 11, 1994, in which you ask us to confirm the amount which must be certified on a Form T3012 ("Application for Refund of RRSP Excess Contributions Made In 19 ") in respect of the above-noted refund from a registered retirement savings plan (RRSP). ...

Francis Attention: XXXXXXXXXX August 2, 1994 Dear Sirs: Re: Technical Interpretation Section 80 of the Income Tax Act This is in reply to your letter of July 12, 1994, wherein you requested our comments on the application of section 80 of the Income Tax Act (the " Act") to a situation where a debtor enters into an economic defeasance arrangement with an arm's length corporation in order to remove the debt from its financial statements. ...

We also enclose for your information a copy of the " Business and Professional Income Tax Guide" which may be of assistance to you. ...

25 January 1995 External T.I. 9330835 F- Inventory Adjustments on Cont of Partners as Propriator Unedited CRA Tags 98(5) PRINCIPAL ISSUES: whether the mandatory and optional inventory adjustments for cash based farmers flow through when a partnership is dissolved and one partner continues to carry on the business POSITION TAKEN: the 28(1)(b) & (c) adjustments do not affect the cost amount of the inventory as defined in 248(1) but the Department will allow the proprietor to take a deduction under 28(1)(f) for the amount established to be inventory under 98(5) REASONS FOR POSITION TAKEN: Decision Summary 6081-3 dated August 27, 1986 XXXXXXXXXX Dear Sir: Re:  Inventory Adjustments on Continuation of a Partnership by a Proprietorship We are replying to your letter of October 12, 1993 concerning the interaction of subsections 28(1) and 98(5) of the Income Tax Act (the Act).  ...