Search - 哈尔滨到北京 公里数

19 September 1989 Administrative Letter 58466 F- Deductibility of Interest Unedited CRA Tags 97(2) 19(1) File No. 5-8466   Blair P. Dwyer   (613) 957-2744 September 19, 1989 Dear Sirs: Re:  Deductibility of Interest on Money Borrowed by Partnership to return Capital to its Partners This is in reply to your letter dated July 26, 1989 asking for our comments on the above-noted subject in light of the Notice of Ways and Means Motion on interest deductibility (released September 29, 1988). ...

25 August 1989 Administrative Letter 58486 F- Regulations to the Income Tax Act Unedited CRA Tags 1100(21)(a)(ii) 19(1) File No. 5-8486   Blair P. Dwyer   (613) 957-2744 August 25, 1989 19(1) Re:  Subparagraph 1100(21)(a)(ii) of the Regulations to the Income Tax Act (Canada) This is in reply to your letter (the "Request Letter") dated August 7, 1989, in which you asked for confirmation of an opinion expressed by an officer of this Department during a telephone conversation on August 6, 1989.  ...

21 June 1990 Administrative Letter 90M06396- Version française du paragraphe 96(1.8): expression "actionnaire désigné" Unedited CRA Tags 96(1.8), 248(1) associé déterminé   Le 21 juin 1990 DIVISION DES MODIFICATIONS BUREAU PRINCIPAL COURANTES Section des services   bilingues Att.: M. ... Bryson Benoit Mandeville   957-8982 OBJET:  Version française du paragraphe 96(1.8) de la Loi de l'impôt sur le revenu Il a été porté à notre attention ce qui semble être une erreur de rédaction dans la version française du paragraphe 96(1.8) ou du paragraphe 248(1) de la Loi de l'impôt sur le revenu (la "Loi"). ...

6 March 1991 Administrative Letter 901876 F- Foreign Accrual Property Income Unedited CRA Tags 91(1), 95(1) foreign accrual property income, 95(2)(f), 91(4) ITR 5907(1.1), 5907(1.3), 5907(1.3)(a)   March 6, 1991   AUDIT PROGRAMS DIRECTORATE              Rulings Directorate International Audits                    O. Laurikainen                                         (613) 957-2129 Attention:  David Burton Subject: Paragraph 95(1)(c) of the Income Tax Act ("Act") Subsection 5907(1.3) of the Regulations to the Act ("Regulations") 24(1) This is in response to your memorandum of August 20, 1990 wherein you request our interpretation of the application of the above provisions to an actual case scenario involving the above corporations.  ...

9 November 1990 Administrative Letter 903116 F- Adjustment to Cost of Property Acquired on Winding-up Unedited CRA Tags 69(11), 88(1), 87, 85(1), 69(5)(b) 24(1) File 903116 Q.15 Subsection 69(11) If subsection 69(11) applies to deem property to be disposed of by the transferor for proceeds of disposition equal to fair market value of the property, what is the transferee's cost of the property in the context of: (a)     a winding-up to which subsection 88(1) applies; (b)     an amalgamation to which section 87 applies; or (c)     a transfer to which subsection 85(1) applies? ...

The specific case that has prompted the enquiry is that of an individual who is 24(1) Our understanding of the rules, as explained in your telephone conversations, governing the payment of benefits is as follows: Entitlement 1)     An individual's entitlement to a benefit is determined only upon receipt of an application for such benefits. 2)     Once approved as having met the criteria for entitlement, the individual's retroactive period of entitlement is determined. 3)     C.P.P. legislation provides that an individual who is otherwise entitled, may receive benefits retroactively up to one year prior to the date of the application. 4)     The retroactive period for old Age Security benefits extends to five years prior to the date of application. 5)     The initial payment of benefits includes an amount in respect of a retroactive entitlement, and subsequent payments reflect his normal monthly entitlement. Cancellation 6)     Cessation of benefit payments is normally triggered by receipt of notification of the death of the recipient. 7)     Occasionally, H & W will receive a request for cancellation of benefit payments for other reasons, in which event the individual's entitlement to further benefits ceases immediately, Suspension 8)     Although there is no legislation which either authorizes or prohibits suspension of benefits payments at the request of the recipient it is your Department's policy to accede to such a request. 9)     Normally, such requests are motivated by a concern that, in a case for example, where an individual temporarily resides in another part of the world where postal service is not reliable, benefit payments may be lost. 10)     Where payments have been suspended, the individual's regular monthly entitlement is diverted to an account bearing the individual's name. 11)     The individual's regular monthly entitlement accumulates in his "account" without interest, until such time as he requests the release of the account and the payment of accrued benefits. Tax Treatment 12)     At the present time, annual information slips for tax purposes reflect the amount of benefit payments actually made in the taxation year i.e. cheques issued. 13)     In the case of the requested release of a suspended account the amount of the lump sum payment is being reflected on the information slip for the year in which the cheque is issued regardless of the period to which the payment relates. ...

19 October 1989 Administrative Letter 58586 F- Retiring Allowance Unedited CRA Tags 56(1), 245(2) 19(1) File No. 5-8586   D.S. Delorey   (613) 957-3495 October 19, 1989 Dear Sirs: This is in reply to your letter of August 24, 1989. ...

22 September 1989 Administrative Letter 58676 F- Association of Corporations Unedited CRA Tags 256(1), 256(1.1), 256(5.1) 19(1) File No. 5-8676   H.K. Tilak   (613) 957-2122 September 22, 1989 Dear Sirs: Re:  Subsections 256(1). (1.1) and (5.1) of the Income Tax Act We are writing in response to your letter of September 8, 1989 in which you requested our opinions with respect to the application of subsections 256(1.1) and 256(5.1) of the Income Tax Act (the "Act") for the purposes of determining whether or not two corporations are associated with each other within the meaning of subsection 256(1) of the Act in the hypothetical situation described below. ...

Gauthier Resource Industries Director Section   John Chan   (613) 952-9019 S. ...

A, buys an interest in AB Partnership, a newly formed limited partnership, for $100. 2.      ... B, is the only general partner. 3.     Mr. A was approached personally by Mr. ... B's personal recommendation. 4.     Pursuant to the partnership agreement, Mr. ...