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4 March 1992 Administrative Letter 9203326 F- T/P Works Outside Canada Less Than 6 Months (7984-1) Unedited CRA Tags 122.3                  March 4, 1992      International Taxation Office     Rulings Directorate      360 Laurier West     K.B. Harding      Room 200C     957-2111      Attention: Doug Wark           920332       Overseas Employment Tax Credit (OETC) Enclosed is a copy of a letter from 24(1) of Calgary. ...

15 May 1991 Administrative Letter 91M05136 F- Relocation Expenses Unedited CRA Tags 6(3)(b) and (c), 6)(1)(a), 110(1)(j) SPEECH ON RELOCATION EXPENSES TO:            24(1) CANADIAN INCOME TAX CONFERENCE DATE:      May 15, 1991 SPEAKER:       B.W. ... NON TAXABLE ITEMS ON RELOCATION (1)       disconnection charges and fees for telephone, t.v. aerial, water, space heaters, air conditioners, barbecues, automatic garage door openers and water heaters; (2)       lease cancellation fees; (3)       mortgage discharge penalties; (4)       mortgage interest, property taxes, heat, hydro, insurance and grounds maintenance costs to maintain the former residence after the move provided that reasonable efforts to sell it are being exercised; (5)       long distance phone charges related to the disposition of the old residence; (6)       loss on the sale of the old residence as stated in paragraph 37 of IT-470R.  The loss on the sale is calculated as the original purchase price + capital additions- net selling price; (7)       interest costs on bridge financing in the purchase of the new residence, provided that all reasonable efforts are exercised to dispose of the old residence; (8)       reasonable interim living expenses at the new location while awaiting occupancy of permanent accommodation at the new location; (9)       legal fees and land transfer tax for the purchase of a new residence; (10)      adjustments and alterations to furniture and fixtures from the old residence to accommodate them in the new residence, including plumbing and electrical changes in the new residence for this purpose; (11)      connection and installation charges for utilities, appliances and fixtures which existed at the old residence; (12)      automobile licence, inspection and drivers permit fees where such items were owned at the former location; (13)      the cost of revision to a will necessitated by the move; (14)      moving costs of personal items and household effects including automobile, boat or trailer; * (15)      the cost of house hunting trips to the new location including child and pet care expenses; * (16)      expenses for moving an employee and household out of a remote place after the work has been completed. ...

Specifically you requested that we address the following: 1)      a situation where no assets were acquired and the project was abandoned by the original applicant; 2)     a situation where assets were acquired but not certified and the project was abandoned by the original applicant; 3)     a situation where assets were acquired and certified but no tax credit claimed and the project was abandoned by the original applicant; 4)     a situation where assets were acquired, certified, the tax credit claimed and/or refunded and the project was abandoned by the original applicant. ... Our review of the criteria indicates the following: a)     "approved project"-      the project must have a total capital cost of depreciable property, determined without reference to subsection 13(7.1) or 13(7.4) of the Act, of not less than $25,000,-      the project must have been approved by the Minister of Regional Industrial Expansion pursuant to an application in writing before July 1988.      As it is the project and not the taxpayer which must be approved, in our opinion a transfer of a project from one taxpayer to another at any time during the project would not affect its status as an "approved project". b)     "approved project property"-      the property must be certified by the Minister of Regional Industrial Expansion to be property that has not been used, or acquired for use or lease, for any purpose whatever before it was acquired by the taxpayer.-      the property must met all other criteria contained in the definition of "approved project property" in subsection 127(9) if the Act.       ...

22 January 1991 Administrative Letter 903576 F- Shareholder Benefit- Single Purpose Corporation Unedited CRA Tags 15(l)                  24(1)                    903576                                         L. ... You have requested our interpretation of this stated policy to the following hypothetical situation: i)        Mr. A is an individual resident in Canada; ii)       Mr. A is the sole shareholder of a Canadian-controlled private corporation ("Holdco") whose sole asset consists of a vacation property (the "Property") located in the United States; iii)      The ownership of the Property meets all of the Department's publicly-stated positions on SPC's noted above; iv)       Mr. ...

7 April 1992 Administrative Letter 9203306 F- Part X.I Tax on Overcntributions to a RRSP Unedited CRA Tags 204.2       5-920330     24(1) D. Duff             (613) 957-8953 Attention:  19(1)  April 7, 1992 Re:  Part X.1 Tax This is in response to your letter of January 27, 1992 requesting an opinion on the interpretation of the term undeducted RRSP premiums as defined in subsection 204.2(1.2) of the Income Tax Act ("Act").  ...

(b)      As indicated in the latter part of subsection 146(8.2) of the Act, a deduction under that subsection is available only where the related amount was included in the recipient's income.  ... (c)      With respect to (b) above, a deduction under subsection 146(8.2) of the Act would be available where the amount received in respect of the excess contribution was included in income under Part I of the Act by virtue of a section 217 election. ... The trustee or issuer of the RRSP should send their application for the annulment to:           Revenue Canada, Taxation     Registrations Directorate     Pension and Profit Sharing Plans Section     400 Cumberland Street     Ottawa, Ontario     K1A 0L8      If the non-resident's RRSP is retroactively annulled, income credited thereto would be subject to Part XIII tax in the year the income was credited to the RRSP. 2.      ...

20 September 1991 Administrative Letter 912376 F- Replacement Property Rules Unedited CRA Tags 13, 44 Dear Sirs Re:  Replacement Property Rules This is in reply to your letter dated July 25, 1991 concerning the application of the replacement property rules in sections 13 and 44 of the Income Tax Act (the "Act") to the series of transactions described below: Facts 1.      2.      24(1) 3.      4.      5.      6.      ...

Des dispositions similaires sont prévues pour la travailleuse qui allaite. 6.       ... On retrouve aussi les définitions suivantes dans le Black's Law Dictionary:      As used in connection with worker's compensation acts, disability is a composite of (1) actual incapacity to perform the tasks usually encountered in one's employment and the wage loss resulting therefrom (i.e. impairment of earning capacity), and (2) physical impairment of the body that may or may not be incapaciting.      ...       ... A ce sujet, vous retrouverez des informations additionnelles aux pages 48 à 50 du Guide de l'employeur Retenues sur la paie, 1992- 1993. 9.       ...

Beith in our memo dated October 11, 1988 (copy attached) and have no reason to change our position as reflected in paragraph 7 of this revision. 1)     Paragraph 3(d)      We suggest that you add the phrase "or loss of employment as the case may be " after "retirement" and change the word "case" to "situation". 2)     Paragraph 4      In the last sentence, dealing with accumulated vacation pay, there is an implied suggestion that such pay may not be ordinary remuneration uf someone other than the employee terminates the employment which is no the case. ... " 4)     Paragraph 9      The reference to the bulletin on rights and things should be IT-212R2 rather than IT-212R. 5)     Paragraph 10      In the Note which discusses pension reform changes, the reference to 1988 should be changed to 1989, based on the Department of Finance Press Releases dated August 19, 1988, and April 27, 1989. 6)     Paragraph 11(a)      The statement concerning "a person related to an employer" is correct but falls short of that which is stated in subparagraph 60(j.1)(iv) and (v) of the Act.  ... " 8)     Paragraph 13      While the amount subject to tax may be reduced by a section 217 election, the amount of withholding may not, as the election is filed subsequent to the payment of the retiring allowance. ...

Francis   957-3496 Attention:  B. Bertrand   File No. 7-4046 Subject: 24(1) Deferred Profit Sharing Plan ("DPSP") This is in reply to your memorandum of March 28, 1989, wherein you requested our opinion in respect of the following situation:-     24(1)-      Subsection 147(9.1) of the Income Tax Act (the "Act") provides that for taxation years commencing after 1981, no deduction can be made in computing the income of the employer for a taxation year in respect of an amount paid by him to a DPSP in respect of a beneficiary described in paragraph 147(2)(k. of the Act.  Contributions to the DPSP appear to have ceased in accordance with subsection 147(9.1) of the Act.--      24(1) The amounts withdrawn by the company are as follows: 24(1) 24(1) You request us to advise you of the tax consequences to the shareholders and the Company. Pursuant to subsection 147(15) of the Act, the following rules will apply to the revoked plan-      the revoked plan is deemed not to be a DPSP or an employee profit sharing plan as of September 30, 1984.-      the trust is taxable on its taxable income for its 1984 and subsequent taxation year.-      the funds withdrawn by the Company will be included in its income in the year of withdrawal. ...