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26 January 1994 Administrative Letter 9332406 F- Non-Resident Trusts and 21-Year Rule Unedited CRA Tags 104(4), 115(1)(b), 115(1)(a)(iii), 104(5.3) International Tax Programs Directorate       Rulings Directorate      957-8953 Attention:  Mr. ...

25 April 1990 Administrative Letter 40896 F- Request for Remission of Tax and Interest Unedited CRA Tags n/a   April 25, 1990 Vancouver District Office Head Office   Technical Review Section   Publications Division Attention:  P.E. ... Details of the amount of 24(1) 1981 and 1982. 2.     Details of the 24(1) assessment in respect of which he is claiming remission. 3.      ... Details of 19(1) age, health and dependants. 5.     19(1) and his dependant's income for the years 1981 and 1989 (to the extent this information is available). 6.      ...

18 June 1992 Administrative Letter 9216996 F- Eligible Contributions To Defined Benefit Pension Plan Unedited CRA Tags REG 8502, REG 8516, 147.1(2), 147.2, REG 8501   7-921699   P. Spice   957-8953 June 18, 1992 Registered Plans DivisionFinancial Industries Division Mrs. Stella Kotlar, Director      Eligible Contributions to Defined Benefit Plan We are in receipt of a letter of December 17, 1991, from 24(1) (copy enclosed) which requests your comments on the matters outlined therein.  ...

Lavigne, Director Benoit Mandeville  Acting Chief 957-8953 Specialized Audit Programs Attention:  Mara Praulins Specified Member of a Partnership This is in reply to your memorandum dated December 8, 1993, in which you asked our opinion whether XXXXXXXXXX The definition of the expression "specified member" in subsection 248(1) of the Income Tax Act (the "Act") provides, among other things, that any member of a partnership will be a "specified member" in a fiscal period or taxation year of the partnership, as the case may be, unless the member (i)      is actively engaged in those activities of the partnership business which are other than the financing of the partnership business, or (ii)      is carrying on similar business as that carried on by the partnership in its taxation year, otherwise than as a member of a partnership, on a regular, continuous and substantial basis throughout that part of the period or year during which the business of the partnership is ordinarily carried on and during which the member is a member of the partnership. ... 2)     Where the partnership engages others to carry out activities of the partnership (such as research), are the activities which relate to management, decision making, direction, promotion, etc., performed by the partner himself? ... 3)     Who makes the decisions related to the daily operation (other than financing) of the partnership? ...

3 March 1992 Administrative Letter 9201626 F- Automobile Allowances Prescribed Amounts Unedited CRA Tags 6(1)(b)(vii.1), 18(1)(r), ITR 7305, ITR 7306   March 3, 1992 Audit Technical Support Division R.B. ... The employer pays the employee a per-kilometre allowance equal to the maximum amounts prescribed by Regulations 7305 and 7306.       ... DathDirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental  Affairs Branch c.c.       ...

12 July 1991 Administrative Letter 910926 F- Interest Deductibility Unedited CRA Tags 20(1)(c)   910926   M.P. Sarazin   (613) 957-2125   July 12, 1991 Dear Sirs: This is in reply to your letter dated April 1, 1991 wherein you requested a technical interpretation regarding the application of paragraph 20(1)(c) of the Income Tax Act (Canada) (the "Act") to the following situation. Facts 1. 2. 3. 4.     24(1) 5. 6. You have requested that we consider the impact of the Department of Finance Information Release 90-171 dated December 20, 1990 and titled "Tax Rules for Deductibility of Interest Extended" (the "Finance Release") and paragraph 7 of Interpretation Bulletin IT-445 in the preparation of our response. ...

20 March 1990 Administrative Letter 74466 F- Assignment of Herring Licences Unedited CRA Tags 14(5) eligible capital expenditure   March 20, 1990 VICTORIA DISTRICT OFFICE HEAD OFFICE Bruce Donaldson Financial Industries Division Chief of Audit C. Robb   (613)957-2744 Attention: Brian Rowden Section 148-1-1 File No. 7-4466 Subject: Assignment of Herring Licenses We are writing in response to your memorandum of October 23, 1989 in which you asked for our comments concerning the assignment of herring licenses. The situation described in your memorandum can be summarized as follows:      A person ("A") owns an unlimited life herring fishing licence, which under the Fisheries Act (Canada) is not transferable. ...

13 September 1990 Administrative Letter 901946 F- Indian Band Council Considered Canadian Municipality Unedited CRA Tags 110(1)(a)(iv), 118.1(1) total charitable gifts   19(1) 901946   Bill Guglich   (613) 957-2102   EACC9656 September 13, 1990 19(1) In a letter dated July 24, 1990, Ms. ...

27 October 1989 Administrative Letter 20166 F- Tax Remission Unedited CRA Tags n/a October 27, 1989   Philip K. Tang   957-9229   File No. 2-0166 19(1) This is in reference to a request made by your accountant in 1988 to our Winnipeg Taxation Centre and later to the Honourable Don Mazankowski regarding the 24(1). ...

16 April 1992 Administrative Letter 9209426 F- RRSP Advantage Unedited CRA Tags 146(2)(c.4)   7-920942   D. ... Delorey   957-8953 April 16, 1992 Registered Plans DivisionFinancial Industries DivisionS. ...