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3 October 1989 Income Tax Severed Letter ACC8594 F- Remission of Income Tax in respect of Certain Income of Individuals Earned in Quebec Unedited CRA Tags n/a     Mr. ...

La note qui est mentionnée dans cette lettre devrait être modifiée comme suit: " $ payé comme indemnités pour accidents du travail- Voir à la rubrique "ligne 130" du Guide d'impôt général les instructions sur la façon de déclarer ces indemnités. ...

Since that article does not define the term "gain" for purposes of the Convention, it is necessary to follow the provisions of paragraph 2 of Article III which states that "... any term not defined therein shall, unless the context otherwise requires and subject to the provisions of Article XXVI (Mutual Agreement Procedure), have the meaning which it has under the law of that State concerning taxes to which the Convention applies". ... We trust this is adequate for your purposes. for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch APPENDIX A Proceeds (April 30, 1989) $150,000 Cost $ 50,000 V-Day Value $ 80,000 Outlays and Expenses $ 10,000 # of months property owned after December 31, 1971 208 # of months property owned between December 31, 1971 and December 31, 1984 156 Proceeds of disposition $150,000 Less: ACB $80,000 Outlays and Expenses $10,000 90,000 Gain liable to tax $ 60,000 Taxable Capital Gain (115(1)(b)) $60,000 X 2/3 $ 40,000 Exempt Portion of Gain (Article XIII(9)) $60,000 X 156/208 $ 45,000 Deduction from Income (115(1)(d) and 110(1)(f)) $45,000 X 2/3 $ 30,000 ...

Since that article does not define the term "gain" for purposes of the Convention, it is necessary to follow the provisions of paragraph 2 of Article III which states that "... any term not defined therein shall, unless the context otherwise requires and subject to the provisions of Article XXVI (Mutual Agreement Procedure), have the meaning which it has under the law of that State concerning taxes to which the Convention applies". ... We trust this is adequate for your purposes. for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch APPENDIX A Proceeds (April 30, 1989) $150,000 Cost $ 50,000 V-Day Value $ 80,000 Outlays and Expenses $ 10,000 # of months property owned after December 31, 1971 208 # of months property owned between December 31, 1971 and December 31, 1984 156 Proceeds of disposition $150,000 Less: ACB $80,000 Outlays and Expenses $10.000 90.000 Gain liable to tax $ 60.000 Taxable Capital Gain (115(1)(b)) $60,000 X 2/3 $ 40.000 Exempt Portion of Gain (Article XIII(9)) $60,000 X 156/208 $ 45.000 Deduction from Income (115(1)(d) and 110(1)(f)) $45,000 X 2/3 $ 30.000 ...

2.       Why isn't there an exception from the "2-year hold" rule in the case of death?  ... 3.a)     Are the shares of X Co. rolled over to Mrs. A on A's death? ... Or, does Revenue Canada still take the view that the Parkes Estate case was properly decided. b)      Had Mr. ...

Vous avez calculé que 30 actions ordinaires de Opco ayant une JVM de 150 000 $ seront transférés à Nouco afin de purifier Opco. ... Ce dividende correspondra au montant de 150 000 $, soit le montant nécessaire afin de purifier Opco. ... Vous expliquez qu'en effet, le revenu gagné attribuable aux actions ordinaires est de 500 000 $. ...

5 October 1989 Income Tax Severed Letter ACC8590 F- Interest Paid to Bank in Korea Exempt from Non-resident Withholding Tax Unedited CRA Tags n/a 19(1) HBW 9412-2-3   HBW 4125-K3   Jim Wilson   (613) 957-2063 October 5, 1989 19(1) We are writing in reply to your letter dated August 11, 1989, concerning the above-noted organization. ...

14 September 1989 Income Tax Severed Letter ACC8577 F- Form 96 for Relief of Swiss Withholding Tax Unedited CRA Tags n/a 19(1) HBW 6591-S4   HBW 6591-4   E.E. Campbell   (613) 957-2067 September 14, 1989 Re:  (Form 96) for relief of Swiss withholding tax Recently you sent us one book each of the French and English version of form 96.  ...

24 October 1989 Income Tax Severed Letter 80296A F- T691- Calculation of Minimum Tax Unedited CRA Tags 127.52(1), 111(1)(b), 111(1.1)   DATE  October 24, 1989 TO  Assessing and Enquiries Directorate FROM  Specialty Rulings Returns Processing Division Directorate   A. ... Legault, Director 957-2135     File No. 8-0296 SUBJECT:  T691 "Calculation of Minimum Tax" We are writing to advise you of an apparent error noted on the above mentioned form in respect of the adjustment permitted under subparagraph 127.52(1)(i)(ii) of the Act for the deduction of net capital losses of other years. ...

10 October 1989 Income Tax Severed Letter ACC8643 F- Guidelines for Remission of Taxes and Write-off Unedited CRA Tags n/a 19(1) HBW 6591-A1   Jim Wilson   (613) 957-2063 October 10, 1989 19(1) Thank you for your letter of August 22, 1989 (your reference fill I concerning settlement of tax debts.  ... With respect to write-off of a debt due to hardship, Treasury Board guidelines stipulate the Minister must be satisfied that the debtor: a)     is incapable of paying the debt in whole or in part and is not reasonably expected to have the capacity to pay the debt in the foreseeable future, and b)     does not own real or personal mortgageable property, is not purchasing property under the Veteran's Land Act and does not own financial assets that could be applied to discharging the debt in whole or in part, and c)     the debtor or the debtor's spouse is in receipt of an income tested or needs tested benefit from the Government of Canada, or      the tax debtor's family income is below the net monthly income level requiring payments from income towards debt as stated in the Guidelines on Payments From Income issued periodically by the Superintendent of Bankruptcy, Department of Consumer and Corporate Affairs. ...