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. $18,000 + $7,200 = $25,200). 17. Under the heading "Preparation of the T4" in example v: Box (C) $25,000 should be replaced with the figure $25,200 in the calculation in brackets. ...

A review of the calculation indicates that, based on all transactions occurring after the "adjustment time" and the above assumptions, only clause 89(1)(b)(iii)(B) of the Act would be applicable and it would result in the inclusion of $25,000 (1/3 * 75% * $100,000) in the CCPC's capital dividend account. 5. ...

It is our view, as outlined in paragraph 13 of Interpretation Bulletin 64R2 (" IT-64R2 "), that the word "control" as expressed in subsection 249(4) of the Act generally means the right of control that rests in ownership of such number shares of a corporation as to give a majority of the voting power in the corporation. ...

7 October 1991 Income Tax Severed Letter- Application of penalties in paragraphs 162(7)(b) and 239(1)(d) where an individual does not comply with subsection 159(2) and thus becomes liable under subsection 159(3) Unedited CRA Tags 159(2), 159(3), 162(7)(b), 239(1)(d) Subject: Application of 239(1)(d) & 162(7)(b) to 159(2) & (3) Further to our telephone conversation of October 18, 1991, with Mr. ... We examined our research files and found that the possibility of applying these penalty provisions in 159(2) & (3) situations had never been addressed by this Directorate. ...

Day (613) 957-2136 912346 Application of 239(1(d) & 162(7)(b) to 159(2) & (3) Further to our telephone conversation of October 18, 1991, with Mr. ... We examined our research files and found that the possibility of applying these penalty provisions in 159(2) & (3) situations had never been addressed by this Directorate. ...

" 2. The following sentence is added following the first sentence of Paragraph 66.1: " At that time, Amalco will also transfer some minor furniture and fixtures to Employeeco. " 3. Paragraph 67 is amended to read as follows: " Amalco will effect a series of increases in the stated capital of the Amalco Class XXXXXXXXXX Preference Shares, the aggregate amount of which will be equal to a portion of the balance in Amalco's CDA immediately before the time of the commencement of such stated capital increases. ... " We confirm that the Canada Customs and Revenue Agency will continue to be bound by the rulings given in the Ruling, notwithstanding the changes described above. ...

5 January 1990 Income Tax Severed Letter HBW65937(WP6) F- OECD Unedited CRA Tags n/a   January 5, 1990 FINANCIAL INDUSTRIES DIVISION Provincial and    International Relations Division Brian Darling David R. Senécal Director 957-2074   HBW 6593-7(WP6) OECD WORKING PARTY #6 TAXATION OF NEW FINANCIAL INSTRUMENTS Further to our memorandum of December 19, 1989, we enclose the final version of the OECD questionnaire on the above-mentioned subject for your consideration and reply. ...

11 September 1989 Income Tax Severed Letter ACC8579 F- Request for Information from Australia Unedited CRA Tags n/a   September 11, 1989 Mr. ... Wilson   957-2063 Attention:  Karen Baldwin   HBW 6591-A1 REQUEST FOR INFORMATION FROM AUSTRALIA This is in response to your memorandum dated April 12, 1989, in which you requested information from the Australian tax authorities regarding compromise settlements.  ...

You describe the following RCA plan: • both employees and employer are beneficiaries; • amounts are to be paid out by the custodian as follows: • employees would receive 50% of the employer's contribution plus an amount equal to 100% of the RCA's income for tax purposes. • the employer would receive 50% of its contributions. ...

In this regard, we enclose a copy of Interpretation Bulletin IT-91R4, Employment at Special Work Site or Remote Work Location and refer you to paragraph 10 which states: "Paragraph 6(6)(b) allows an employee to exclude from income (...) an allowance (not in excess of a reasonable amount) received for transportation expenses incurred by the employee, (...) if the employee received board and lodging, or a reasonable allowance in respect of board and lodging, from his or her employer (...) " As this does not appear to be the case in your situation, we agree that the daily travel allowance is taxable employment income to be reported on the employee's T-4. ...