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7 June 1990 Income Tax Severed Letter HBW40003C F- Federal and Provincial Income Tax Rates Unedited CRA Tags n/a 19(1) HBW 4000-3   Jim Wilson   (613) 957-2063 June 7, 1990 Dear   19(1) We are writing in reply to your letter dated May 15, 1990, in which you requested details of federal and provincial income tax rates. ...

Worker's Compensation Board to Issue Tax Deductible Charitable Donation Receipts Unedited CRA Tags 110.1(1)(a), 110.1(1)(b), 118.1(1) total charitable gifts 19(1) File No. 5-8406   R.B. Day   (613) 957-2136 August 24, 1989 Dear 19(1) We are writing in reply to your letter of July 18, 1989, wherein you requested our views as to whether or not the Worker's Compensation Board of British Columbia (the "Board") would be authorized to issue tax deductible charitable donation receipts with respect to donations received by the Board. ...

21 September 1989 Income Tax Severed Letter ACC8674 F- Canada-Netherlands Income Tax Convention Unedited CRA Tags 56(1)(a), 110(1)(f)(i), 126(1)(b)(ii)(A)(III) 19(1) HBW 4125-N1   Jim Wilson   (613) 957-2063 September 21, 1989 Dear 19(1): We are writing in reply to your letter of August 17, 1989, concerning the Canada-Netherlands Income Tax Convention. ...

21 September 1989 Income Tax Severed Letter ACC8709 F- Fair Market Value of Subsidized Accommodations and Utilities made Available to Certain Employees Unedited CRA Tags n/a 19(1) HBW 4903-1   B. Fioravanti   (613) 957-2073 September 21, 1989 19(1) We are writing in reply to your letter of June 26, concerning the determination of the fair market value of subsidized accommodations and utilities made available to certain employees of the your 24(1) It is our view that the formula you propose produces a subsidized value rather than the fair market value as required under the Income Tax act.  ...

19 June 1990 Income Tax Severed Letter 900465 F- Roll-over of Farm Property to Children- Vesting Indefeasibly Unedited CRA Tags 70(9) 24(1) File No. 900465   G. ... Our Comments: a)     In our view the Peardon case was determined on the facts of that case, which was in any case involving a spousal trust. The facts in your example involve a testamentary trust for the children and a life interest, in the house only, for the spouse. b)     The Department's views on the meaning of the term "vested indefeasibly" are contained in Interpretation Bulletin IT-449R. ...

1 June 1989 Income Tax Severed Letter 32475A F- Taxability of Indians Unedited CRA Tags n/a   June 1, 1989 TO- VICTORIA DISTRICT OFFICE Specialty Rulings D.K. ... Thornley   (613) 957-2101   File No. 3-2475 SUBJECT: 19(1) We are enclosing an advance income tax ruling request on behalf of the above from 19(1).  ... Wheeler for Director Small Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch c.c.      ...

16 October 1989 Income Tax Severed Letter 58544 F- Gift by Will Unedited CRA Tags 118.1(5), 118.1(6), 104(4), 107 19(1) File No. 5-8544   A.B. Adler   (613) 957-8962 October 16, 1989 Dear Sirs: This is in reply to your letter dated August 16, 1989 in which you requested our views concerning the application of subsections 118.1(5), 118.1(6) and 104(4) of the Income Tax Act ("Act") to the following hypothetical situation. 1.      ... There will be no power to encroach on capital for B or any other person. 2.      ...

Excluded premiums is defined at 146.01(1) to mean any premium: • designated under paragraphs 60(j),(j.1),(J.2) or (l); • transferred directly from an RRSP,RPP, RRIF or DPSP; • deducted under 146(6.1) (prescribed premiums); or • deducted in computing the individuals 1991 income. 4. ...

In the Re: title after XXXXXXXXXX ("Individual B")- XXXXXXXXXX add: "XXXXXXXXXX ("Individual C")- XXXXXXXXXX " 2. ... In the first sentence of paragraph 7 the word "XXXXXXXXXX " is deleted and replaced with the word "XXXXXXXXXX ". 6. ... In subparagraph (b) of paragraph 8 delete "." and replace with "; and". ...

APPENDIX Example 1- Successful Auction "AA" Composite Commercial Pater Rate 10% Ceiling is therefore 110% of 10% or 11% 100 shares outstanding #1 10 shares #2 20 shares #3 30 shares #4 30 shares #5 10 shares 100 Bids and Sell Orders from Existing Holders #1 Continue to hold 10 shares if new rate is at least 7.000 % #2 sell 20 shares #3 Continue to hold 30 shares if new rate is at least 7.250% #4 Continue to hold 30 shares if new rate is at least 7.300% #5 Continue to hold 10 shares if new rate is at least 7.250% Bid to Buy Orders from Potential Holders #1 Buy an additional 20 shares if new rate is at least 7.000% #6 Buy 20 shares if new rate is at least 7.125% #7 Buy 15 shares if new rate is at least 7.100% #8 Buy 50 shares if new rate is at least 7.350% #9 Buy 60 shares if new rate is at least 7.400% #10 Buy 40 shares if new rate is at least 7.275% Available shares 100- # subject to firm hold =100- 0 =100 Sufficient Clearing Bids- Calculation (6) 20 shares bid for by Bidder #1 20 shares bid for by Bidder #6 15 shares bid for by Bidder #7 50 shares bid for by Bidder #8 60 shares bid for by Bidder #9 40 shares bid for by Bidder #10 205 exceeds 20 shares offered to be sold by Bidder #2 195 Then rand in order beginning with lowest rate until at least 100 shares can be sold: Bidder Shares Order 1 10 Continue to hold if new rate at least 7.000% 1 20 Buy if new rate is at least 7.000% 7 15 Buy if new rate is at least 7.100% 6 20 Buy if new rate is at least 7.125% 3 30 Continue to hold if new rate at least 7.100% 5 10 Continue to hold if new rate at least 7.250% 105 Winning Bid Rate is 7.250% Acceptance and Rejection of Bids, Bids to Buy and Sell Orders 1) Existing Holders with bid rates higher than 7.250% or that offered to sell without regard to the Established Rate, must sell Bidder #4 sells 30 shares Bidder #2 sells 20 shares 2) Existing Holders with bid rates lower than 7.250%, hold Bidder #1 holds 10 shares 3) Potential Holders with a bid to buy order with a rates lower than 7.250%, buy Bidder #1 buys 20 shares Bidder #6 buys 20 shares Bidder #7 buys 15 shares 4) Existing Holders with bids to buy order with a rate equal to 7.250%, must sell enough to meet any extra demand Bidder #3 wants to hold 30 shares Bidder #5 wants to hold 10 shares 40 but only 100- (#1- 30) (#6- 20) (#7- 15) 35 remain 5 Each must sell a proportionate number Bidder #3 gives up 30/40 x 5 = 4 Bidder #5 gives up 10/40 x 5 = 1 After settlement, shareholders are as follows: Bidder #1 holds 30 shares Bidder #2 holds 0 shares Bidder #3 holds 26 shares Bidder #4 holds 0 shares Bidder #5 holds 9 shares Bidder #6 holds 20 shares Bidder #7 holds 15 shares 100 Each will receive a dividend of 7.250% for the nest quarter. Example 2- Failed auction "AA" composite Commercial Paper Rate 10% Ceiling is therefore 110% of 10% or 11% 100 shares outstanding #1 10 shares #2 20 shares #3 30 shares #4 30 shares #5 10 shares 100 Bid and Sell orders from Existing Holders #1 Sell 10 shares #2 Sell 20 shares #3 Continue to hold 30 shares if new rate at least 9.250% #4 Continue to hold 30 shares if new rate at least 11.250% #5 Continue to hold 30 shares if new rate at least 9.250% Bids to Buy Orders from Potential Holders $6 Buy 20 shares if new rate is at least 10.125% Available Shares = 100- # subject to firm hold = 100- 0 = 100 As the number of bid orders by Potential Holders specifying rates equal to or lower than the ceiling rate 20 shares bid by bidder $6 is less than the number offered to be sold by Existing Holders regardless of the dividend rate plus the number bid by Existing Holders at rates higher than the ceiling rate: 10 shares offered to be sold by Bidder #1 20 shares offered to be sold by Bidder #2 30 shares bid for by Bidder #4 at a rate above the ceiling rate 60 sufficient clearing bids do not existing. ... Acceptance and Rejection of Bids, Bids to Buy and Sells 1) Existing Holders with bid rates equal to or lower than 11% continue to hold Bidder #3 holds 30 shares Bidder #5 holds 10 shares 2) Potential Holders with bid rates equal to or lower than 11% purchase Bidder #6 purchases 20 shares 3) Existing Holders with bid rates higher than 11% or that offered to sell without regard to the Established Rate, sell a pro-rata number to meet demand Bidder #1 wants to sell 10 shares Bidder #2 wants to sell 20 shares Bidder #4 wants to sell 30 shares buy only 20 shares need to be sold Each sells a proportionate number: Bidder #1 sells 10/60 x 20 = 3 Bidder #2 sells 20/60 x 20 = 7 Bidder #3 sells 30/60 x 20 = 10 After settlement, shareholding are as follows: Bidder #1 holds 7 Bidder #2 holds 13 Bidder #3 holds 30 Bidder #4 holds 20 Bidder #5 holds 10 Bidder #6 holds 20 100 Each will receive a dividend of 11.000% for the next quarter. ...