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31 May 1993 External T.I. 9227675 F- Interest Deductibility Change of Income Source Unedited CRA Tags 20(1)(c)   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Interest Deductibility and Change of Income Source This is in reply to your letter dated September 21, 1992 wherein you requested the Department's opinion regarding the application of paragraph 20(1)(c) of the Income Tax Act (the "Act"). ...

18 June 1993 External T.I. 9302775 F- Attribution and Marriage Breakdowns Unedited CRA Tags 74.1, 74.2   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Capital Gains Attribution This is in reply to your letter of February 2, 1993 in which you requested our views on the application of the capital gains attribution rules in subsection 74.1(2) of the Income Tax Act (the Act). ...

13 May 1993 External T.I. 9305255 F- Clearance Certificate by the Trustee of a RRSP Unedited CRA Tags 159(2), 160.2(1)   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sir/Madam: This is in reply to your letter of January 27, 1993 to our Toronto District Office received on February 19, 1993 for reply concerning the application of subsection 159(2) of the Income Tax Act (the "Act") in the situation outlined in your letter. ...

10 June 1993 External T.I. 9234305 F- Short Sales Unedited CRA Tags 260   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Short Sales This is in reply to your letter of November 12, 1992, and recent telephone conversations (Brake/XXXXXXXXXX) relating to the timing of recognition of a gain or loss in respect of a short sale in circumstances where the shares to be acquired for delivery have been delisted, or where the company has become insolvent or bankrupt, and it is not possible to close the short position. ...

9 July 1993 External T.I. 9311215 F- SBC- Assets Used in Active Business Unedited CRA Tags 248(1) small business corporation   XXXXXXXXXX Attention:  XXXXXXXXXX Dear XXXXXXXXXX RE:  Definition of Small Business Corporation ("SBC") This is in reply to your letter of April 7, 1993 in which you requested the Department's interpretation of the definition of SBC in subsection 248(1) of the Income Tax Act. ...

11 August 1993 External T.I. 9318255 F- Employment Benefits- Ontario PST on Insurance Unedited CRA Tags 6(1)(a), 6(1)(f)   XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Ontario Sales Tax on Insurance Premiums This is in reply to your letter of June 21, 1993 in which you requested confirmation of the correct tax treatment of amounts paid by the employer in respect of the province of Ontario's proposed retail sales tax levy on insurance premiums. ...

16 August 1993 External T.I. 9319665 F- Retiring Allowance Unedited CRA Tags 5, 248(1) retiring allowance   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Retiring Allowances This is in reply to your facsimile transmission of July 8, 1993, concerning the payment of severance to employees who may be called back to work for the employer. ...

One test is that the individual perform all or substantially all the duties of his employment outside Canada "... in connection with a contract under which the specified employer carried on business outside Canada with respect to... ...

2 September 1993 External T.I. 9324005 F- Taxable Benefit Plans- Purchase of Vacation Leave Unedited CRA Tags 6(1)(a)   XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Tax Treatment of Vacation in lieu of Salary This is in reply to your letter of August 20, 1993 in which you requested our views as to the tax implications of purchasing additional vacation leave in lieu of a salary increase. ...

22 September 1993 External T.I. 9303885- Revenu gagné et réalisé Unedited CRA Tags 55(2), 55(5)(b) SESSION SPÉCIALE DE L'APFF: 55(2) ET 55(3) DE LA LOI ET TRANSACTIONS PAPILLONS APFF — 10 février 1993 Question 8 Le revenu gagné ou réalisé est attribué à chacune des actions selon un calcul au pro-rata. ...