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Example #1 You propose to calculate the taxable benefit pursuant to section 80.4 of the Act for each of the two taxpayers as follows: (i) (Prescribed + (Subsidy- (Total of Actual- Total Taxable Benefit Interest) Interest) Interest Paid by Both Employer and Employee) 11% + (1% + 1%)- 12%- 1% (ii) The net taxable benefit is 1% for the two employees combined. ... Employer A contributes 1% and Employer B contributes 2%), the following calculations;- in your view, will apply: (i) (Prescribed + (Subsidy- (Total of Actual- Total Taxable Benefit Interest) Interest) Interest Paid by Both Employer and Employee) 11% + (1% + 2%)- 12%- 2% (ii) The net taxable benefit is 2% for the two employees combined. ... Example #2 Employee of Employer A Paragraph 80.4(1)(a): 11% 80.4(1)(b): 1% 80.4(1)(c): 12% 80.4(1)(d): nil Then (a) + (b)- (c)- (d)- 12%- 12%- nil Employee of Employer B Paragraph 80.4(1)(a): 11% 80.4(1)(b): 2% 80.4(1)(c): 12% 80.4(1)(d): nil Then (a) + (b)- (c)- (d)- 13%- 12%- 1% Accordingly, the employee of Employer A is not assessed a taxable benefit while the employee of Employer B will be assessed a taxable benefit based on 1% provided the two employers are not related to each other. ...

7 December 1989 Income Tax Severed Letter ACC8828 F- Remittance of Personal Passport Unedited CRA Tags n/a   89M12327   December 7, 1989 Mr. ...

1 August 1990 Income Tax Severed Letter 9015143A F- Proposed Leasing Transaction Unedited CRA Tags 212(13) 19(1) 3-901514   T. Murphy   (613) 957-2747   EACC9364 August 1, 1990 Dear Madam: Re: Advance Income Tax Ruling Request 24(1) This is in reply to your ruling request of July 6, 1990 wherein you requested rulings, among others, that  24(1) In our telephone conversation of July 12, 1990 we advised you that we will not rule on the proposed leasing transaction described in your ruling request. ...

1 December 1989 Income Tax Severed Letter ACC8962 F- Technology Transfer Agreement with Italy Unedited CRA Tags n/a   19(1) 89M12450   E.E. Campbell   (613) 957-2067 December 1, 1989 Dear 19(1) Re:  Request for Certification In the request for certification from 24(1) of November 21, 1989 it was requested that it be confirmed that all the provisions included in the Convention between Canada and Italy are applicable to the TTA, which is the Technology Transfer Agreement. ...

The evidence must clearly indicate that the series of transactions commenced before April 22, 1980 but generally where transactions similar to the following take place after April 22, 1980 the Department will, until it is proven otherwise, take the view that the series of transactions commences after April 22, 1980: •     Incorporation of a holding company- Transfer of shares to a holding company- Issuing of high-low preference shares- The payment of a dividend that was not part of the terms of a purchase and sales agreement entered into before April 22, 1980. 3. ...

7 December 1989 Income Tax Severed Letter ACC8828A F- Remittance of Personal Passport Unedited CRA Tags n/a   89M12326   December 7, 1989 Mr. Joseph Khoury Legislative and Section 145-1-2 Intergovernmental Montreal District Office Affairs Branch Provincial and International   Relations Division 19(1) Please find enclosed your Canadian Personal Passport which you had given to our department in order to obtain a special passport for your trip abroad. ...

5 December 1989 Income Tax Severed Letter ACC4131F1B F- Certificate of Coverage under Canada-Sweden Social Security Agreement Unedited CRA Tags n/a   19(1) 19(1) HBW 4131-F1   Al Watson   (613) 957-2072 Attention: December 5, 1989 Dear Sirs: Re:  19(1) It is our understanding from your letter of September 22, 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 Finish social security schemes by his employer.  ... Savage A/Director Provincial and International Relations Division c.c.      ...

5 December 1989 Income Tax Severed Letter ACC4131F1A F- Certificate of Coverage Pursuant to Canada-Sweden Social Security Agreement Unedited CRA Tags n/a   19(1) 19(1) HBW 4131-F1   Al Watson   (613) 957-2072 December 5, 1989 Dear Sirs: Re:  19(1) It is our understanding from your letter of August 1, 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.  ... SavageA/Director Provincial and International Relations Division c.c.      ...

Our views regarding the issues raised in your submission follow: 1.      ... The question of beneficial ownership of specific prints must be established on the basis of all the facts in each particular case. 2.      ... A widely accepted definition of "fair market value" is that contained in Black's Law Dictionary, 6th edition, which reads as follows:      "the amount at which property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of the relevant facts". ...

If the corporation commences to carry on the business of SR & ED on a date in Year A after the time at which it had ceased to carry on its prior business and all or substantially all of its revenue during remainder of Year A is derived from the prosecution of SR & ED, will the prosecution of SR & ED be considered to be a business of the corporation to which SR & ED is related in Year A. 3. ... Will the interest income received be regarded as being revenue from the prosecution of SR & ED and thus not prevent the prosecution of SR & ED from being a business of the corporation to which SR & ED is related. ... Where the taxpayer can show that all or substantially all (90% or more) of its revenue in the current year is from the prosecution of SR & ED, the prosecution of SR & ED would generally be considered to be a business of the taxpayer to which SR & ED is related. 2. ...