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29 December 1989 Income Tax Severed Letter ACC8855 F- Non-profit Organization Tax-Exempt Status Unedited CRA Tags 138(1), 149(1)(l), 135   89M12481   December 29, 1989 OTTAWA DISTRICT OFFICE Business and General Audit Review Section Division J.J. ...

28 May 1991 Income Tax Severed Letter 91M05055 F- Foreign Affiliate Regulations- "90 Day- Rule" Unedited CRA Tags ITR 5901(2) FOREIGN AFFILIATE REGULATIONS- " 90 DAY- RULE " QUESTION A corporation resident in Canada ("Canco") owns 30% of the shares of a corporation ("FA") resident in the United States.  ...

30 October 1989 Income Tax Severed Letter 20166A F- Tax Remission Unedited CRA Tags n/a   October 30, 1989 TO- Winnipeg Taxation Centre FROM- Technical R.W. ... Tang   (613) 957-9229   File No. 2-0166 SUBJECT: TAX REMISSION 19(1) The request for tax remission by the above noted taxpayer, made by 19(1) in a letter to your Taxation Centre on October 28, 1988, has been granted by her Excellency the Governor General in Council recently. ...

12 January 1990 Income Tax Severed Letter 58970A F- Automobile Manufacturing Industry Plan Unedited CRA Tags n/a 19(1) File No. 5-8970A   J.A. Szeszycki   (613) 957-2103 January 12, 1990 Dear Sirs: Re:  24(1) We are writing in response to your letter of October 25, 1989 and further to your meeting of November 22, 1989, with Jack Szeszycki of this office in which you described the details of the  24(1) As was indicated at the meeting we were in the process of locating the results of a previous review done with respect to a similar plan in place at another automobile manufacturer.  ... Yours truly, for DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch c.c.      ...

12 December 1989 Income Tax Severed Letter ACC58153A F- Continuing Investigation Unedited CRA Tags n/a 19(1) HBW 5815-3   Al Watson   (613) 957-2072 December 12, 1989 Dear Sir: Re:  24(1) 19(1) On July 25, 1988, we wrote to your office concerning a continuing investigation into the income tax affairs of the above-noted taxpayers.  ... Savage A/Director Provincial and International Relations Division Enclosure c.c.      ...

Social Security Agreement Unedited CRA Tags n/a 19(1) HBW 4131-U3   Al Watson   (613) 957-2072 December 5, 1989 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 will expire on May 16, 1990.  19(1) employer has indicated that the work assignment will not be concluded within 60 months and have asked for a one year extension.  ... Savage A/DirectorProvincial and InternationalRelations Division c.c.      ...

11 January 1990 Income Tax Severed Letter 80339A F- Loss from Farming Where Chief Source of Income Not Farming Unedited CRA Tags 31(1)   January 11, 1990 B.J. ... Tremblay   (613) 957-2095   File No. 8-0339A Subject: Subsection 31(1) of the Income Tax Act Enclosed is a memorandum from the Appeals Branch concerning questions submitted from a legal firm to the Department of Justice requesting their views on the objective of subsection 31(1) of the Act. ...

SUBJECT: REFUND OF PREMIUMS SECTION: 146(l)(h), 146.3(6.1)] PRAIRIE TAX CONFERENCE May 19 & 20, 1992 DRAFT/EBAUCHE QUESTION 14 What is the Department's interpretation of Paragraph 146(l)(h) and Subsection 146.3(6.1) of the Income Tax Act of Canada (the "Act"), specifically as it relates to the phrase "child or grandchild", in the following example: • Mother has a Registered Retirement Income Fund ("RRIF"). • Mother passes away, there is no surviving spouse. • Daughter is over the age of 18, but is financially dependent on mother, i.e. she has no income and lives in mother's home. • Daughter is not physically or mentally infirm. • Daughter is the beneficiary of mother's estate. • The daughter is the natural child of the mother as defined in Section 252(1)(a) of the Act. ...

Since Paul spent more than 183 days in Canada he will be deemed to be a resident of Canada and will be subject to tax in Canada on his world income ($18,000 + $15,000 + $1,000 = $34,000). ...

Question # 3 sous-question # 1 (réponse suggérée) i)La date de conversion d'un terrain vacant considéré pour son propriétaire comme étant un bien en immobilisation, en bien en inventaire, est une question de fait. ... Question # 3 sous-question # 2 (Réponse suggérée) i)Les conséquences fiscales découlant de cette transaction doivent être analysées en deux étapes. ... Question # 15 i)Cette question a déjà été posée lors la Session spéciale de l'APFF 1993 portant sur les paragraphes 55(2) et 55(3) de la Loi (question # 34). ...