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1 February 1990 Income Tax Severed Letter 9195 F- Form T691A Minimum Tax Supplement- Multiple Jurisdiction Unedited CRA Tags n/a                                      February 1, 1990   Assessing & Enquiries Directorate  Technical Interpretations J.M. ... Middleton             Division               957-9230 Nancy Kelly Subject: Form T691A Minimum Tax Supplement- Multiple Jurisdiction In accordance with your request of October 25, 1989, we have reviewed the above-mentioned form. ...

5 December 1989 Income Tax Severed Letter ACC4131F1C F- Certificate of Coverage under Canada-Finland Social Security Agreement Unedited CRA Tags n/a   19(1) 19(1) HBW 4131-F1   Al Watson   (613) 957-2072 Attention: 19(1) December 5, 1989 Dear Sirs: Re:  19(1) It is our understanding from your letter of September 25, 1989, that 24(1) We are pleased to accept, on behalf of the competent authority for Canada, that the aforementioned person will be covered under the Finnish social security schemes by his employer.  ... Savage A/Director Provincial and International Relations Division c.c.       ...

2 August 1987 Income Tax Severed Letter 32445 F- Joint Venture Versus Partnership Unedited CRA Tags n/a LEGAL SERVICES- TAXATION         Resource Industries                                     Section Attn: C.T.A. ... Gauvreau       General Counsel             957-8955                                     3-2445 24(1) Subject: Joint Venture versus Partnership We are writing to advise you that the transactions contemplated by the legal opinion request which we previously submitted to you dated June 19, 1989, are no longer proposed transactions; consequently, we are withdrawing our request. ...

1 October 1990 Income Tax Severed Letter 9005075 F- Mortgage Investment Corporations Unedited CRA Tags 130.1(6), 248(1) cost amount 24(1) 5-900507   C. ... In particular, paragraph (a) of the definition of cost amount provides that:      where the property was depreciable property of the taxpayer of a prescribed class, that proportion of the undepreciated capital cost to him of property of that class at that time that the capital cost to him of the property is of the capital cost to him of all property of that class. Paragraph (b) provides that:      where the property was capital property (other than depreciable property) of the taxpayer, its adjusted cost base to him at that time. ...

18 January 1993 Income Tax Severed Letter 9232797 F- Equivalent to Married Amount Unedited CRA Tags 118(1)(b)(i) Mississauga District Office Luba Komadina Training Coordinator 169-3-1  923279 Equivalent to Married Amount We are writing in reply to your memorandum of October 29, 1992, wherein you requested our opinion on the application of paragraph 118(1)(b) in the following situations: 1.      ... In this regard you wish to know if they are both eligible to claim the equivalent-to- married amount in the year of reconciliation. 2.      ... This position is set out in the last sentence of paragraph 12 of IT-513:      "... where previously separated spouses become reconciled during a taxation year, for all tax credits under subsection 118(1) they are regarded as married persons who lived together throughout the year. ...

Les mots " retraite " et " pension " ne sont pas définis dans la Loi et l'on doit s'en remettre à la jurisprudence. ... Le mot " emploi " n'est pas défini dans la Convention. ... " Le mot " emploi " doit donc être défini selon le droit du Canada concernant les impôts et ce, en vertu du paragraphe 248(1) de la Loi qui prévoit qu'un " emploi " est " un poste qu'occupe un particulier au service d'une autre personne ". ...

26 September 1989 Income Tax Severed Letter ACC8685 F- Certificate of Coverage under Canada-Germany Social Security Agreement Unedited CRA Tags n/a     IX 3 A(1) F-191.221.1(509) 19(1) A. Watson    (613) 957-2072   HBW 4131-G1 September 26, 1989 RE: APPLICATION OF ARTICLE 10 IN THE CASE OF 19(1) This is in answer to your letter dated June 28, 1989, in which you request our concurrence in special arrangements under Article 10 of the Social Security Agreement between Canada and the Federal Republic of Germany. ... SavageActing DirectorProvincial and InternationalRelations Division c.c.      ...

11 September 1989 Income Tax Severed Letter ACC8860 F- Certificate of Coverage under Canada-Germany Social Security Agreement Unedited CRA Tags n/a   IX 3 A(1) F-191.221.1(509) 19(1) HBW 4131-G1   A. Watson   (613) 957-2072 September 11, 1989 This is in answer to your letter dated June 28, 1989, in which you request our concurrence in special arrangements under Article 10 of the Social Security Agreement between Canada and the Federal Republic of Germany. ... Savage A/DirectorProvincial and InternationalRelations Division c.c.:       Pauline Tourangeau Source Deductions AW/sg19(1)File CopySequence FileAuthor's CopyChrono file ...

6 September 1989 Income Tax Severed Letter ACC8647 F- Refunds of Tax to Canadian Employees of Chrysler Unedited CRA Tags n/a     September 6, 1989 Mr. ... Watson   957-2072   HBW 6591-U3 24(1) As requested, we wrote to the Internal Revenue Service on January 19, 1989, requesting clarification of some of the comments that appeared in the Windsor Star of Thursday, December 1, 1988, concerning refunds of tax to Canadian employees of Chrysler. ...

13 December 1989 Income Tax Severed Letter ACC8816 F- Remission of Penalty Unedited CRA Tags n/a     89M12263   December 13, 1989 MISSISSAUGA DISTRICT HEAD OFFICE TAXATION OFFICE Technical Interpretations G.R. Mohr Division Director Esta Mikhail   (613) 952-3606 19(1) 19(1)  Member of Parliament, Ms. ...