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20 August 1990 Ministerial Correspondence 900404 F- Scientific Research and Experimental Development Unedited CRA Tags 37(1) 24(1) 900404   C.R. Bowen   (613) 957-2096 Attention: 19(1) EACC9294 August 20, 1990 Dear Sirs: Re: Scientific Research and Experimental Development ("SR&ED") We are writing in reply to your letter of April 10, 1990 and further to our telephone conversation of July 16, wherein you requested our comments on the phrase "entitled to exploit the results of such SR&ED" in subsection 37(1) of the Income Tax Act (the "Act").  ...

23 February 1990 Ministerial Correspondence 59374 F- Income Attribution Rules Unedited CRA Tags 74.1, 103(1.1), 74.5(1), 97(2) 19(1) File No. 5-9374   A.W. Larochelle   (613) 957-2140 February 23, 1990 Dear Sirs: Re:  The Income Attribution Rules Subsections 74.1 and 103(1.1) of the Income Tax Act (the "Act") This is in reply to your letter concerning the attribution rules in section 74.1 of the Act. ...

18 October 1989 Ministerial Correspondence 58444 F- Wittholding of Tax- Wrongful Dismissal Payment Unedited CRA Tags 56(1), 60, 153(1)(c), 248(1) retiring allowance 19(1) File No. 5-8444   J.D. Jones   (613) 957-2104 October 18, 1989 Dear Sirs: Re:  Paragraph 153(1)(c) of the Income Tax Act (the "Act") This is in reply to your letter of July 26, 1989, wherein you requested our confirmation of your understanding of the requirements relating to the withholding of tax pursuant to paragraph 153(1)(c) of the Act in the following situation. ...

11 July 1989 Ministerial Correspondence 58104 F- Income Tax Treatment of Payments to Employees on Leave Unedited CRA Tags 60(j.1), 248(1) retiring allowance 19(1) File No. 5-8104   A. Adler   (613) 957-8962 July 11, 1989 Dear Sirs: This is in reply to your letter dated May 15, 1989 concerning the income tax treatment of certain payments to employees who go on "pre-retirement leave". ...

29 January 1990 Ministerial Correspondence 56704 F- Interest Rate Cap Unedited CRA Tags 9, 12(1)(a)(i), 20(1)(m)(ii), 18(9)(a)(i), 18(9)(b) 19(1) File No. 5-6704   M.M. Trotier   (613) 957-8953 January 29, 1990 Dear Sirs: Interest Rate Cap This is in reply to your letter of October 11, 1988 wherein you requested our comments as to the income tax implications to a bank with respect to its participation as vendor or purchaser of an interest rate protection agreement.  ...

20 July 1989 Ministerial Correspondence 58034 F- Mortgage Investment Corporation Unedited CRA Tags 130.1(6) 19(1) File No. 5-8034   A. Seidel   (613) 957-8960 July 20, 1989 Dear Sir: This is in reply to your letter of May 3, 1989, requesting information with respect to Mortgage Investment Corporations ("MIC") as defined in subsection 130.1(6) of the Income Tax Act (the "Act"). ...

12 February 1990 Ministerial Correspondence 59474 F- Capital Gains Exemption and Insufficient Dividend Test Unedited CRA Tags 55(2), 55(3)(a), 84(3), 85(1), 110.6(8), 125(7) Canadian-controlled private corporation, 248(1) cost amount, 248(10), 251(2), 251(6), ITR 6205(1)(a), 6205(2) 19(1) File No. 5-9474   S. Shinerock   (613) 957-2108 February 12, 1990 Dear Sirs: Re:  Subsection 110.6(8) of the Income Tax Act (the "Act") We refer to your letter of December 6, 1989, wherein you requested our views on the application of subsection 110.6(8) of the Act and subsection 6205(2) of the Income Tax Regulations ("ITR") to the following hypothetical situation. ...

19 September 1989 Ministerial Correspondence 58564 F- Dissolution Unedited CRA Tags 85(1), 87(1), 89(1) taxable Canadian corporation, 98(2), 98(3), 98(5) 19(1) File No. 5-8564   S. Leung   (613) 957-2116 September 19, 1989 Dear Sirs: Re:  Request for Technical Interpretation of certain provisions of the Income Tax Act (the "Act") We are writing in response to your letter of August 21, 1989 wherein you requested our comments on your interpretation of the application of certain provisions of the Act in the two hypothetical situations outlined below. ...

14 June 1989 Ministerial Correspondence 57754 F- Stock Option Plan Unedited CRA Tags 110(1)(d), 7(3), 7(1) 19(1) File No. 5-7754   J.D. Jones   (613) 957-2104 June 14, 1989 Dear Sirs: Re:  Paragraph 110(1)(d) and Subsection 7(3) of the Income Tax Act This is in reply to your letter of March 22, 1989, wherein you requested a technical interpretation with respect to paragraph 110(1)(d) subsection 7(3) of the Income Tax Act (the Act) as it relates to 24(1) (1987) Stock Option Plan (the Plan) submitted in draft form with your letter. ...

Income Tax Convention on Canadian Tax and Filing Obligations Unedited CRA Tags 69(3), 150(1), 150(2), 115 24(1) 900414   G. Arsenault   (613) 957-2126 Attention: 19(1) EACC9245 August 30, 1990 Dear Sirs: Re:  Canadian Tax and Filing Obligations U.S.- Canada Tax Convention This is in reply to your letter dated March 20, 1990 to the Non-Resident Taxation Division.  ...