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23 May 1990 Administrative Letter 900396 F- Impact of Employer Sponsored Child Care Assistance Unedited CRA Tags n/a   May 23, 1990   ACC9031 24(1) File No. 900396   J.D. Jones   957-2104 19(1) Dear Sirs: Re:  Health and Welfare Canada Study Impact of Employer Sponsored Child Care Assistance under the Income Tax Act This is in reply to your letter of April 12, 1990, wherein you requested our comments concerning the income tax treatment of benefits provided by employers to employees in respect of child care in a variety of hypothetical situations. ...

18 October 1990 Administrative Letter 59586 F- Impact of Partnership on Pre-acquisition Losses Unedited CRA Tags 111(5), 87(2.1) 24(1) 5-9586   L.A. ... Situation No. 1 1.     Company B acquired all the shares of Company A in an arm's-length transaction. 2.      ... The income and losses of the partnership, based on the relative net fair market values of the assets contributed by Companies A and C, are allocated two-thirds to Company A and one-third to Company C.       ...

4 October 1989 Administrative Letter F3296 F- Non-resident Income Earned in Canada Unedited CRA Tags n/a   October 4, 1989 Mr. ... McColm   957-2068   File No. F-3296 IT Bulletin Project No. 1658 Non-Resident Income Earned in Canada Revision of IT-420R2 We have reviewed the above draft project and have no comments with respect to policy matters, current or pending, that are relevant to positions taken in the draft. ...

6 July 1990 Administrative Letter F3696 F- Election Re Tax Withholding from Capital Gain or Dividend Unedited CRA Tags 153(1)(n)   July 6, 1990 Mr. ... Allington   957-2064   F-3696 Paragraph 153(1)(n) For your information we are enclosing copies of correspondence which we received from the Specialty Rulings Directorate concerning whether a taxpayer may elect under paragraph 153(1)(n) to have an amount withheld from a capital gain or dividend. ...

18 July 1990 Administrative Letter 901146 F- Part XIII Tax on Interest Payments Unedited CRA Tags 212(1)(b)   July 18, 1990 Appeals Branch Financial Institution Appeals and Referrals Division Section   J.P. Dunn   957-8961 Attn. W. Lynn Section Chief 901146   EACC9420 Section:  24(1) We are writing in response to Dave Turner's memorandum of June 25, 1990 concerning the application of paragraph 212(1)(b) of the Income Tax Act (the "Act") 24(1) It is our opinion that, in the circumstances described in your correspondence, Part XIII of the Act is applicable to the interest payments. ...

19 April 1990 Administrative Letter 5900366 F- Designations by Testamentary Trusts in respect of Beneficiary Unedited CRA Tags 104(13.1), 108(1) income interest, 108(1) cost amount, 122(2)(d) 19(1) File No. 5-900366   D.S. Delorey   (613) 957-3495 April 19, 1990 Dear Sirs: Re: Subsection 104(13.1) Designations Testamentary Trusts This is further to our letter of January 12, 1990 concerning designations by a trust under subsection 104(13.1) of the Income Tax Act (the "Act"). ... The payment may be made either by (a)     reimbursing the trustee, (b)     giving the trustee a cheque made payable to the Receiver General, or (c)     receiving a net amount from the trustee; i.e., an amount equal to the beneficiary's share of the income of the trust less his share of the taxes. ...

The majority of the voting shares of Company X are owned by company Y and will continue to be so owned throughout the time that the Plan is in operation. 2.      ... Such purchase by an Employee may give rise to a taxable benefit pursuant to section 6 or section 7 of the Act. 3.      ... Under the Plan, the Employees also have the option of selling shares issued under the Plan directly to Company X rather than to Sidecar Co. 4.      ...

15 June 1992 Administrative Letter 9214436 F- Use Of T2200 By Employee For Office In Home Unedited CRA Tags 8(13), 8(10), 8(1)(f), 8(1)(h)   921443   A. Humenuk   (613) 957-2134 June 15, 1992 T1 Programs DivisionBusiness and General DivisionAssessment of Returns Directorate Attention: Michelle Desmarais-Markham Office in Home Expense for Employees This is in reply to your memorandum dated May 7, 1992 concerning the interaction of paragraphs 8(1)(f) and 8(1)(i) and subsections 8(10) and 8(13) of the Income Tax Act. ... However, the employee would not be required to submit a form in subsequent years for expenses claimed under paragraph 8(13)(c) which were denied in prior years by reason of paragraph 8(13)(b) since the expenses which are carried forward would have met all the criteria for a deduction in the prior year except for that of paragraph 8(13)(b) of the Act.                            21(1)(b) B.W. ...

28 August 1989 Administrative Letter 58496 F- Completion Deadline of Transaction Extended Unedited CRA Tags n/a 19(1) Your File No. 86/2450   Our File No. 5-8496   M. Vallée   (613) 957-2093 August 28, 1989 Dear Sirs: Re:  24(1) This is in reply to your letter of August 4, 1989, wherein you requested that we extend the time for the completion of the proposed transactions described in the Previous Ruling. ...

Trust to Canadian Beneficiary Unedited CRA Tags Treaty US Article XII, Treaty US Article XIII, Treaty US Article XXI January 6, 1992 MEMO FOR FILE Rulings Directorate   Foreign Section   Jim Wilson   7-913250 Article XII & XIII of the Canada-U.S. ...