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15 January 1987 Income Tax Severed Letter AC71282 F- Grazing Leases and Permits   7-1282   January 15, 1987 CALGARY DISTRICT OFFICE                   HEAD OFFICE                                          Leasing and Financing                                            Section                                           M. Siegel                                           (613) 957-2746 Attention:     G.C. Hoard           Chief of AuditThis is in reply to your memoranda of November 13 and December 19, 1986 concerning the tax treatment of grazing leases andgrazing permits. ...

17 November 1989 Income Tax Severed Letter AC4131F2A F- CPP Extension Unedited CRA Tags n/a 19(1) HBW 4131-F2   Al Watson   (613) 957-2072 November 17, 1989 Messieurs, 24(1) As this is an assignment that is to another company we are of the view that the concurrence of your office is required in accordance with Article VIII(1) of the Agreement.  ... Savage A/Director Provincial and International Relations Division Attachments c.c.       ...

25 September 1989 Income Tax Severed Letter 74267 F- Investment Income Unedited CRA Tags 149(5), 149(5)(e)(i)                                              SEPT 25 1989   WINNIPEG DISTRICT OFFICE                     Small Business and S. Campbell                                    General Division Audit Division                               Bill Guglich                                              (613) 957-2102                                                7-4267 24(1) This is in reply to your memorandum of August 21, 1989 concerning the deductibility of membership fee discounts in calculating property income for purposes of subsection 149(5) of the Act. (1) (2) (3)    24(1) 4) (5) Our Comments Subparagraph 149(5)(e)(i) of the Act requires the Club to calculate its income on the assumption it had only property income. ...

12 December 1989 Income Tax Severed Letter ACC8821 F- Survey Unedited CRA Tags n/a   89M12277   December 12, 1989 Mr. Gilles Gaignery Provincial and International Co-ordinator Relations Division Access to Information and Legislative and Privacy Division Intergovernmental   Affairs Branch      E.E. Campbell     (613) 957-2067 24(1) We have completed the attached survey to the best of our ability.  ...

Does a one-employee corporation qualify?      You state that you have a number of incorporated doctors and dentists who may be able to take advantage of a self-funded leave of absence.  While allay, their practice would usually be carried on by a locum tenens. 2.     What happens if the leave does not start within six years of commencing the funding?       ...

28 November 1989 Income Tax Severed Letter 58321A F- Compensation Capital Gain or Business Income Unedited CRA Tags 39(1) 19(1) File No. 5-8321A   A.W. Larochelle   (613) 957-2140 November 28, 1989 19(1) Re:  24(1) This is in reply to your letter of June 28, 1989 and further to our telephone conversation of August 29, 1989 in which you requested our views respect to 24(1) Our understanding of the facts relating to this matter as described in your letter and from our conversation are as follows: 1.      2.     24(1) Based on the above information you have asked if the compensation received would be classified as a capital gain or ordinary business income for income tax purposes. ...

Schedule A FAT and the Utilization of Losses in a Consolidated Group Year 1 Year 2 FA1 Active Business Income $500 ($300) FA2 FAPI $100 $100 Consolidated Income $600 ($200) Taxable Income after loss is carried back $400- Taxes paid by group after the loss is carried back (assuming a foreign tax rate of 50% on all income) $200- FAT (FA2 pays FA $50 in year 1 & year 2) $ 50 $ 50 Schedule B FAT and Capital Gains-     FA1 has a capital gain of $100 which is taxed at a rate of 30%. ... As all the amount of FAT has been utilized, there is no FAT to be carried forward as a result of the gain.-     The effect on the surplus pots is as follows: Exempt Surplus Taxable Surplus 1/2 of gain $50 $50 Less: Applicable portion of foreign taxes paid 7 23 Net increase $43 $27-     The underlying foreign tax would be $23 and a tax free dividend of $70 could be paid to Canada with $43 coming from exempt surplus and $27 (offset by $23 underlying foreign tax) coming from taxable surplus.-     Note: The relevant tax factor is 2.174. ... Schedule C FAT and Tax Credits Year 1 Year 2 FA1 Active business income $100 $100 Investment income (FAPI) $100 $100 Total income $200 $200 Tax at 50% on all income $100 $100 Less: Investment tax credit related to active business income $ 50 $100 Taxes paid assuming tax credits are fully utilized $ 50 NIL FAT $ 50 NIL ...

12 October 1989 Income Tax Severed Letter ACC8587 F- Canada-France Tax Convention Unedited CRA Tags n/a   October 12, 1989 S. Kotler Provincial and International Director Relations Division Registered Pensions and Legislative & Intergovernmental Deferred Income Plans Affairs Branch   Al Watson Attention: N. Pettifer 957-2072      HBW 4125-F1 24(1) PARAGRAPH 5, ARTICLE XXIX CANADA-FRANCE INCOME TAX CONVENTION As competent authority, we have been asked to agree that the pension plans referred to in the attached submission correspond to pension plans which would be recognized for income tax purposes in Canada. ...

7 September 1989 Income Tax Severed Letter ACC8696 F- Evaluation of Performance Unedited CRA Tags n/a   19(1) HBW 2044-2-8   Al Watson September 7, 1989 Dear Sir: 19(1) We have received a request from 19(1)   to provide an evaluation report on his performance while on assignment with Revenue Canada, Taxation.  ... Savage A/Director Provincial and International Relations Division Attachments c.c.        ...

Income Tax Convention on Sales of Records and Tapes by Performing Artist Unedited CRA Tags Treaty US Article 26   HBW 4125-U3   David R. Senécal   (613) 957-2074 Dear      19(1) This is in reply to your letter of July 31, 1990, wherein, pursuant to paragraph 3 of Article XXVI of the Canada-U.S. ... Yours sincerely, Christine SavageActing DirectorProvincial and International Relations Division no.      3-83File copySequence fileAuthor's copyChrono file (2)Reading file ...