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"La corporation est réputée avoir disposé, (...) de chaque bien (...) qui lui appartenait (...). ...

23 November 1988 Income Tax Severed Letter AC56721 F- Limited Partnership At-Risk Rules Unedited CRA Tags 96(2.2)                                                   5-6721                                                   C.A. Bowen                                                   (613) 957-2094   Dear Sirs: We are writing in reply to your letters of October 4 and 5, 1988, wherein you..requested our comments in respect of the application of the limited partnership at-risk rules in paragraphs 96(2.2)(c) and 96(2.4)(a) of the Income Tax Act (the "Act"). ...

A "A" 100 1 000 $ 1 000 $ 1 000 000 $ M. B "A" 100 1 000 $ 1 000 $ 1 000 000 $.../2 000041 8. ... Ledit choix est effectué sur un certain nombre d'actions seulement afin d'utiliser totalement l'exemption sur le gain en capital disponible pour M.A soit 500 000 $. ...

10 October 1989 Income Tax Severed Letter ACC8642 F- Pensions Received from Britain While Residing in Canada Unedited CRA Tags n/a   19(1) HBW 8199-4-U1   Jim Wilson   (613) 957-2063 October 10, 1989 19(1) We are writing in regards to your letter of August 2, 1989, concerning the tax treatment of pensions upon immigration to Canada.  ... The following comments may be useful when calculating taxes payable. 1.      ... Those aged 65 or over may claim an additional credit of $550.00. 2.      ...

Senécal   (613) 957-2074   HBW 4125-U November 27, 1989 Dear 19(1): We will keep you advised of our discussions. ...

27 July 1990 Income Tax Severed Letter 9009915 F- Residence of Trusts Unedited CRA Tags n/a 24(1) 5-900991   Sean Finn   (613) 957-2746 Attention:  19(1)   July 27, 1990 Dear Sirs: Re:  Residence of Trusts Interpretation Bulletin IT-447 This is in reply to your letter dated May 28, 1990, in which you requested our opinion on a question of the residence of a trust and in particular on the application of the administrative position contained in paragraph 7 of Interpretation Bulletin IT-447, dated May 30, 1980, to a particular fact situation.  ...

(B) XXXX & (C) 21(1)(a) & (b) Chief Mines, Oils & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch Attachments ...

In 1986, the FMV of the AB partnership increased to $ 25,000 (all related to goodwill) and Mr. ... B $ 10,000 ($ 25,000 x 40%) for his 40% partnership interest. Mr. A continued to carry on the business as a sole proprietor. ... A can apply to goodwill will be $ 5,000 by virtue of subparagraph 98(5)(d)(iii) of the Act. ...

Thomson 952-9853 Attention: David Loney FILE 992878 DOSSIER SUBJECT: OBJET: RRSP Trustee fees to safeguard assets We are responding to your request for our opinion on a request from a trust company to amend several of its specimen RRSP plans to include the following: " XXXXXXXXXX; " In our opinion, reasonable expenses incurred by the trustee in the exercise of its fiduciary duty with regard to the plan assets may be reimbursed from the assets of the plan. ...

During 1988, the taxpayer had net rental income of NIL computed as follows: Gross rental income $50,000 Expenses: Maintenance $ 5,000 Interest 40,000 Depreciation- 5,000 50,000 Net rental income $- With respect to this hypothetical situation you have requested our opinion as to which of the five following computations of CNIL would be valid relative to the definition of "investment expense" and "investment income" in subsection 110.6(1) of the Act. (1) (2) (3) (4) (5) Investment expenses $50,000 $40,000 $50,000 $40,000 paragraph (a) Less: Investment income- 50,000 50,000 paragraph (d) CNIL $, $40,000 $- $50,000 $(10,000) Our Comments It is our opinion that alternative 3 would reflect the proper calculation of CNIL in this situation. ...