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Hillier, A/Director Directorate   R.C. O'Byrne E. Pringle 957-2126   File No. 7-4494 Subject: Treaty Exempt Income and Alternative Minimum Tax This is in reply to your memorandum of November 7, 1989 in which you asked for our views on the application of the minimum tax rules of the Income Tax Act (the "Act") to a treaty exempt capital gain. The situation 1.     A United States ("U.S.") resident disposed of a property located in Canada during 1988. 2.      ... Income Tax Convention (1980) (the "Convention"). 3.     The U.S. resident filed a 1988 Canadian Income Tax Return wherein he reported the taxable portion of the capital gain and an equal offsetting deduction under subparagraph 110(1)(f)(i) of the Act. 4.      ...

28 July 1989 Ministerial Correspondence 73924 F- Mine Reclamation Expenditures Unedited CRA Tags 18(1) 19(1) File No. 7-3924   G.R. ... Our understanding of the salient provisions of the reclamation Act is as follows: 1.      ... Paragraph 18(1)(m) of the Act provides that no deduction shall be made in respect of "...any amount... paid or payable by virtue of an obligation imposed by statue to (i)     Her Majesty in right of... a province, (ii)     an agent of Her Majesty in right of... a province, or (iii)     a corporation, commission or association that is controlled by Her Majesty in right of... a province or by an agent of Her Majesty in right of... a province as a royalty, tax..., lease rental or bonus or as an amount, however described, that may reasonable be regarded as being in relation to (iv)     the acquisition, development or ownership of a Canadian resource property, or (v)     the production in Canada of... ...

7 September 1989 Ministerial Correspondence 58184 F- Home Relocation Loans Unedited CRA Tags 80.4(1), 110(1)(j), 248(1) home relocation loans 19(1) File No. 5-8184   S. Short   (613) 957-2134 September 7, 1989 Dear Madam: Re:  Paragraph 110(1)(j) of the Income Tax Act (the "Act") This is in reply to your correspondence dated June 2, 1989, wherein you asked whether certain loans would qualify as "home relocation loans" as defined in subsection 248(1) of the Act and whether recipient employees of these loans would be entitled to a deduction under paragraph 110(1)(j) of the Act. ... Accordingly, an individual must have "... received a loan or otherwise incurred a debt by virtue of the office or employment.. ...

20 August 1990 Ministerial Correspondence 900754 F- Employee Stock Purchase Plans Unedited CRA Tags 7, 110(1)(d) 24(1) 900754   A. Humenuk   (613) 957-2135 Attention: 19(1) EACC9316 August 20, 1990 Dear Sirs: Re:  Employee Stock Purchase Plans We are replying to your letter of March 29, 1990 addressed to source Deductions Division which has been referred to us for reply. ... Yours truly, for DirectorBusiness and General DivisionRulings DirectorateLegislative and IntergovernmentalAffairs Branch enclosure c.c.      ...

23 May 1990 Ministerial Correspondence 58474 F- German Corporation Tax Credit Unedited CRA Tags 126, 20(11) 24(1) File No. 5-8474   O. Laurikainen   (613) 957-2125 19(1) May 23, 1990 Dear Sirs: Re: German Corporation Tax Credit This is in response to your letters of July 31, 1989 and April 2, 1990 wherein you enquired about the Canadian tax treatment of the german corporation tax credit. Your enquiry involves the following set of facts: 24(1) 6.     Germany, pursuant to paragraph 4 of Article 10 of the Canada-Germany Income Tax Agreement (1981) (the "treaty") may tax the dividend in the hands of the taxpayer at full personal tax rates. 24(1) Based on our review of the information you have submitted, we would conclude that the German corporations tax that has become creditable to the shareholder by virtue of the payment of the dividend (the "German corporation tax credit"), would represent constructive receipt of income by the shareholder. ...

Brown   957-2082 19(1) June 5, 1990 Dear Sirs: This is in reply to your letter of march 16, 1990 concerning small business corporations. ... You request our comments on the following: i)     Would the mortgage be considered used in an active business carried on primarily in Canada? ... Our comments on the above questions are as follows: i)     The mortgage does not appear to be used in the business cycle. ...

24 October 1990 Ministerial Correspondence 58954 F- General Anti-avoidance Rule and IC 88-2 Unedited CRA Tags 245 24(1) 5-8954    S.J. ... In particular you asked the following: (a)     To what sources will the Department look to discover Parliament's intention as to the consequences of specific provisions of the Act? (b)     Would the acquisition of shares of a profitable corporation by a loss corporation be subject to subsection 245(2) of the Act? ...

16 November 1989 Ministerial Correspondence F3344 F- Retiring Allowances- Revision of IT-337R2 Unedited CRA Tags n/a   November 16, 1989 Publications Division Current Amendments and   Regulations Division Mr. ... Sheerin  957-2079 Director   F-3344 Interpretation Bulletin Project #1507 Retiring Allowances Revision of IT-337R2 This is in reply to your memorandum of October 16, 1989 prepared by T. ...

22 September 1989 Ministerial Correspondence 58584 F- Capital Gains Exemption- Deemed Residence in Canada Unedited CRA Tags 110.6(5), 110.6(2), 110.6(2.1), 110.6(3), 70(5) 19(1) File No. 5-8584   G. ... Our Comments 1)     An individual who dies in 1989 after becoming a resident and after disposing of capital property in that year is not entitled to a capital gains exemption on any capital gain arising from that disposition.  ... There is no capital gains exemption entitlement. 3)     Where the individual disposes of capital property in 1989 after becoming resident he must report his capital gain in that year.  ...

15 November 1989 Ministerial Correspondence 91014 F- Foreign Currency Loans Unedited CRA Tags 80.4(3) DECISION SUMMARY File No. 9101-4   Personal and General Section   J.D. ... Background 24(1) Problem 21(1)(b) Position 24(1) Rationale 1.     The law in this area is quite clear. In order to come within the exempting provisions of subsection 80.4(3) of the Act, the taxpayer must show that the loan bears a rate of interest that would have been agreed upon, having regard to all circumstances, between arm's length parties. 24(1) 2.     23  ...