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Muirhead, Chief, Non-Residents & Business & Property Income Section, Non-Corporate Rulings & Publications Directorate, Legislation Branch, Revenue Canada, Taxation, 88 Metcalfe Street, Ottawa, Ontario K1P 5L7 Dear Ms. ...

8 September 1989 Income Tax Severed Letter AC88002- Explication des écart entre le remboursement d'impôt demandé et ce lui accordé Unedited CRA Tags n/a 19(1) HBW 8800-2   HBW 1046-6   David R. Senécal   (613) 957-2074 Le 8 septembre 1989 Monsieur, L'honorable Otto Jelinek, ministre du Revenu national, m'a demandé d'examiner vos déclarations d'impôt pour 1984 et 1985 afin de vous fournir certains détails quant à leur cotisation. ...

18 July 1990 Income Tax Severed Letter 74508A F- Penalty for Repeated Failure to Report Unedited CRA Tags 163(1)   July 18, 1990 Assessing and Enquiries Business and General Examination Division Division   J.D. Jones   957-2104 W.S. Hume Director 7-4508A Subsection 163(1) Penalty This is further to our memorandum of July 14, 1989 (copy attached) in which you requested our comments on the interpretation of subsection 163(1) of the Act. 21(1)(b) 23 B.W. ...

1 March 1988 Income Tax Severed Letter RCT 5-5155 F Unedited CRA Tags 25(1), 85(2), 99(2) Dear Sirs, RE:     Sections 25 & 99 of the Income Tax Act (the "Act") This is in reply to your letter of November 18, 1987 and following our telephone conversation (Gillman XXX of February 16, 1987 concerning the election of a year-end by an individual who is a member of a partnership after having the partnership elect to rollover all of its assets to a taxable Canadian corporation in virtue of subsection 85(2) of the Act. ...

12 December 1989 Income Tax Severed Letter ACC8819 F- Mandate of Revenue Canada, Taxation Unedited CRA Tags n/a 19(1) 89M12274   E.E. Campbell   (613) 957-2067 December 12, 1989 Re:  19(1) Further to our letter of November 1, we attach a copy of the letter which went out to 19(1) advising of the action proposed. ... It's mandate can be summarized as follows: 1.     To collect the taxes imposed under the law by encouraging voluntary compliance. 2.      ...

RESPONSE R & D quality of audits have always been a district office responsibility.  Consistency of application of R & D audit policies from district to district is ensured by Head Office through:     i)   Development and communication of audit policies and procedures;     ii)  staff training;     iii) technical support and assistance. The responsibility for resolution of whether something qualifies as R & D will remain with the R & D advisor in Ottawa. ...

5 December 1989 Income Tax Severed Letter ACC4131G1A F- Certificate of Coverage under Canada-Germany Social Security Agreement Unedited CRA Tags n/a   19(1) 19(1) HBW 4131-G1   Al Watson   (613) 957-2072 December 5, 1989 Dear 19(1) Re:  APPLICATION OF ARTICLE 10 IN THE CASE OF 19(1) This is in answer to your letter, dated October 24, 1989, in which you request our concurrence in special arrangements under Article 10 of the Agreement on Social Security between Canada and the Federal Republic of Germany. ... Savage A/Director Provincial and International Relations Division c.c.      ...

6 October 1989 Income Tax Severed Letter 89M10036 F- Special Passport Unedited CRA Tags n/a   October 6, 1989 Mr. John Archer Legislative and Examination Division Intergovernmental   Affairs Branch   Janet Burke SPECIAL PASSPORT 19(1) Please find enclosed your Canadian Special Passport which has been issued for your trip abroad. ...

26 January 1990 Income Tax Severed Letter 32901A F- Non-Resident Withholding Tax on Interest Payment Unedited CRA Tags 212(1)(b)(ii)(C)(I)   January 26, 1990 ST. ... Scott Financial Industries Division Chief of Audit Kevin Donnelly   (613) 957-3400 Attention:  Jim Hillier   File 3-2901A Subject: Advance Ruling Request   24(1) Enclosed is a copy of a ruling request from the St. ... Clark ChiefLeasing & Financing SectionFinancial Industries DivisionRulings Directorate ...

In the example above, this amount will be 50% of ($100 + $1000), or $550. Under the provisions of section 84.1(1)(b) of the Act, the required reduction in the adjusted cost base of the shares received will be as follows: The lesser of Adjusted cost base of Opco shares $1000 Paid-up capital of Holdco shares $ 550 lesser- $ 550 minus Paid-up capital of Opco 100 ACB reduction $ 450 ACB of Holdco shares as otherwise elected under Section 85 $1000 Less 84.1(1)(b) reduction 450 Revised adjusted cost base of shares of Holdco $ 550 Since the revised adjusted cost base of $550 is equal to the paid-up capital of the Holdco shares, it is your understanding that the taxpayer can have Holdco redeem shares up to the total amount of the paid-up capital, $550 tax free. ... Accordingly, on the redemption, the following tax consequences will arise: Amount paid or deemed to be paid $1500 Less: Paid-up capital 550 Deemed dividend pursuant to subsection 84(3) of the Act $ 950 Proceeds of disposition pursuant to 54(h) ($1500- $950) $ 550 Less: Adjusted cost base 550 Capital Gain $ 0 It is therefore our view that on the redemption of the Holdco's shares Mr. ...