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1 November 1991 Income Tax Severed Letter 91M11260 F- Deduction of Accruals under GAAP for Mining Site Restoration Costs QUESTION 1.        ... Such accruals are necessary to achieve proper matching of revenues and expenses.     ... ANSWER 1.        The requirement by provinces for site restoration, by itself, does not give rise to an expense.  ...

Bertrand 957-3496 SUBJECT: XXX 7-4046 Deferred Profit Sharing Plan ("DPSP") This is in reply to your memorandum of March 28, 1989, wherein you requested our opinion in respect of the following situation: • XXX • Subsection 147(9.1) of the Income Tax Act (the "Act") provides that for taxation years commencing after 1981, no deduction can be made in computing the income of the employer for a taxation year in respect of an amount paid by him to a DPSP in respect of a beneficiary described in paragraph 147(2)(k) of the Act. Contributions to the DPSP appear to have ceased in accordance with subsection 147(9.1) of the Act. • XXX • XXX The amounts withdrawn by the company are as follows: • XXX • XXX You request us to advise you of the tax consequences to the shareholders and the Company. Pursuant to subsection 147(15) of the Act, the following rules will apply to the revoked plan • the revoked plan is deemed not to be a DPSP or an employee profit sharing plan as of September 30, 1984. • the trust is taxable on its taxable income for its 1984 and subsequent taxation year. • the funds withdrawn by the Company will be included in its income in the year of withdrawal. ...

An example of this tax reduction is as follows: Canadian Employment Income $59,000 Interest Income from Canadian sources $1,100(A) Less: Expenses incurred to earn the Canadian interest income 100 1,000(B) Net Income $60,000 Deductions in computing taxable income 10,000 Taxable Income $50,000(C) Total Federal and Provincial Taxes Payable 40- Rate C X 40%- $50,000 X 40% = $20,000(D) Taxes Payable relating to Canadian Interest Income B/C X D- $ 1,000/$50,000 X $20,000 = $ 400(E) Limitation under paragraph 2 of Article 11 of the Convention 10% X A- 10% X $1,100 = $ 110(F) Tax Reduction E- F $400- $110 = $ 290(G) Note: The tax reduction should be apportioned on a reasonable basis between the Federal and Provincial taxes payable. Revised Taxes Payable D- G $20,000- $290 = $19.710 Please note that this approach produces the correct net income amount which is used for the purposes of calculating various tax credits. ...

Social Security Agreement Unedited CRA Tags n/a 19(1) HBW 4131-U3   Al Watson   (613) 957-2072 December 5, 1989 Dear 19(1) This is to request your concurrence in granting an extension of the sixty-month period of detachment under Article V(2)(a) of the Canada-United States Social Security Agreement in the following case: CANADIAN EMPLOYER:  24(1) WORK LOCATION:  24(1) EMPLOYEE:  19(1) The initial period covered by certificate will expire on January 1, 1986 to December 31, 1990.  ... Savage A/Director Provincial and International Relations Division c.c.       ...

Social Security Agreement Unedited CRA Tags n/a 19(1) HBW 4131-U3   Al Watson   (613) 957-2072 December 5, 1989 Dear 19(1) This is to request your concurrence in granting an extension of the sixty-month period of detachment under Article V(2)(a) of the Canada-United States Social Security Agreement in the following case: CANADIAN EMPLOYER:  24(1) UNITED STATES WORK LOCATION:  24(1) EMPLOYEE:  19(1) The initial period covered by certificate was August 1, 1984, to July 31, 1989.   ... Savage A/DirectorProvincial and International Relations Division c.c.        ...

Social Security Agreement Unedited CRA Tags n/a 19(1) HBW 4131-U3   Al Watson   (613) 957-2072 December 5, 1989 Dear 19(1) Re:  19(1) This is to request your concurrence in granting an extension of the sixty-month period of detachment under Article V(2)(a) of the Canada-United States Social Security Agreement in the following case: CANADIAN EMPLOYER:  24(1) WORK LOCATION IN THE UNITED STATES:  24(1) EMPLOYEE:  19(1) DATE OF BIRTH:  19(1) The initial period covered by certificate was August 1, 1984, to July 31, 1989.   ... Savage A/Director Provincial and International Relations Division c.c.       ...

25 October 1989 Income Tax Severed Letter ACC8636 F- Sovereign Immunity Unedited CRA Tags n/a 19(1) Jim Wilson   (613) 957-2063   HBW 9412-2-3 October 25, 1989 19(1) Re:  24(1) Sovereign Immunity We are writing in reply to your letter of October 3, 1989, concerning sovereign immunity for the 24(1)   (hereinafter referred to as 24(1) 24(1) Revenue Canada, Taxation considers sovereign immunity exemptions in respect of investment income earned by a government of a foreign country. ... We will require the following information before we can grant exemption under the Doctrine of Sovereign Immunity. (1) (2)      24(1) 24(1) We regret our reply cannot be more favourable at this time. ...

A)        Les frais payés à un hôpital public ou à un hôpital privé agréé sont admissibles à titre de frais médicaux en vertu de l'alinéa 118.2(2)a) de la Loi. ... C)        Finalement, on retrouve à l'alinéa 118.2(2)e) de la Loi, les frais qui sont engagés dans une école, une institution ou un autre endroit. ... CONCLUSION À     la suite de ces commentaires, il apparaît clairement que chaque situation constitue un cas d'espèce. ...

28 November 1990 Income Tax Severed Letter HBW4125U31B F- Tax-Exempt Dividend Service System Unedited CRA Tags n/a 19(1) HBW 4125-U3-1   Al Watson   957-2072 November 28, 1990 19(1) We are writing further to your letter dated September 19, 1990, and attachments thereto, concerning the assignment of a Tax Exempt Dividend Service number hereinafter referred to as "TEDS", to 24(1) which fall into the following categories:-     Canadian Municipalities and-     Foreign Governments or entities. ... Keith HillierDirectorNon-Resident Taxation Division360 Lisgar StreetOttawa, OntarioK1A 0L8      Attention: Jack Steinman We trust that our comments are of assistance. ... Non-Resident Taxation Division file copy reading file sequence fileaccess to info (2)control # state disc U.S. #1 ...

The facts of the situation, as understood from the correspondence attached to your memorandum as well as telephone conversations with Brenda Scarcella of Winnipeg, are as follows: * XXX * XXX * XXX * XXX Paragraph 118(4)(d) of the Act provides that no amount may be claimed in respect of a dependant under paragraph 118(1)(d) unless an amount is included in income under subsection 56(5) [family allowance] in respect of that dependent. ...