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24 October 1989 Administrative Letter 89M10016 F- Ontario Student Assistance Program Unedited CRA Tags n/a   October 24, 1989 Mr. ... Fioravanti   957-2073 Attention: R.J. Menard Ontario Student Assistance Program 19(1) As discussed please find attached the request from the 19(1) concerning the tax returns of the above referred taxpayers. ...

4 July 1991 Administrative Letter 910946 F- Scientific Research and Experimental Development- Deductibility of Capital Expenditures Unedited CRA Tags 37(1)(b) Dear Sirs: Re:  Paragraphs 37(1)(b) and 37(7)(c) of the Income Tax Act (the"Act") This is in reply to your letter dated April 4, 1991 in which you requested our view as to whether certain expenditures incurred by a corporate taxpayer for the construction of a processing facility will be considered to be for scientific research and experimental development ("SR & ED") pursuant to paragraph 37(1)(b) of the Act. The question of whether any capital expenditure incurred in the construction of a particular facility is deductible for SR & ED purposes would depend on whether or not such expenditure was incurred for (and was all or substantially all attributable to) the provision of premises facilities or equipment for the prosecution of SR & ED in Canada.  ...

16 October 1989 Administrative Letter F2746 F- Disposition of a Building and Control of a Corporation Unedited CRA Tags 13(21.1), 111(4)(e), 111(5.1)   October 16, 1989 Mr. ... Burnett/957-2078 Division   File No. F-2746 Subsection 13(21.1) of the Income Tax Act This is in response to the memorandum of January 27, 1989 prepared by R. ...

27 February 1990 Administrative Letter F3476 F- Interpretation Bulletin Project Number 1344 Unedited CRA Tags n/a   February 27, 1990 Mr. ... Burnett 957-2078   File No. F-3476 Interpretation Bulletin Project Number 1344- Receipt of Inducements and Reimbursements and Other Assistance- Revision of IT-273R We have reviewed the above draft project and have no comments with respect to policy matters, either current or pending, that are relevant to positions taken in the draft. for B.J. ...

2 November 1989 Administrative Letter 58916 F- Information Circular 89-4 on Tax Shelter Reporting Unedited CRA Tags n/a   November 2, 1989 To: Ed Gauthier From: Head Office Director Specialty Rulings Special Audits Division Directorate Policy and Systems Branch C.R. Bowen 957-2096   File No. 5-8916 Subject: Information Circular 89-4 We are forwarding the attached letter to you in order that your Division can respond directly to 19(1) concerning his questions posed on tax shelter reporting. ...

3 November 1989 Administrative Letter 89M11206 F- Tax Remission Unedited CRA Tags n/a   November 3, 1989 TO- SCARBOROUGH DISTRICT OFFICE FROM- Technical Mr. ... Tang   (613) 957-9229 Attention:  Mr. B. Riordan Manager Public Affairs SUBJECT:  TAX REMISSION 19(1) Further to our recent telephone conversation, we enclose herewith a copy of the Remission Committee's minute on this case.  ...

14 September 1993 Administrative Letter 9325156 F- Employer Contributions to an RPP Unedited CRA Tags 147.2(2)   Registered Plans DivisionFinancial IndustriesS.M. ... " With respect to that wording, XXXXXXXXXX raises the following three questions: 1.      ... 3.     Is a recommendation by the actuary required or may the valuation report merely set out the contribution requirements? ...

24 October 1989 Administrative Letter 80296 F- Minimum Tax and Application of Net Capital Losses Unedited CRA Tags 111(1)(b), 11(1.1), 111(8) net capital loss, 1127.52(1)(i)(ii), 127.52(1)(d)   October 24, 1989 To: Appeals Branch From: Business and R.A. ... Humenuk   957-2135 Attention: B.A. Chisholm Section Chief Appeals and Referrals DivisionAppeals and Referrals Division  File No. 8-0296 Subject: Minimum Tax and the Application of Net Capital Losses We are responding to your memorandum of June 5, 1989, concerning the amount deductible as a net capital loss under subparagraph 127.52(1)(i)(ii) of the Income Tax Act (the Act). 24(1) The calculation on form T691 "Calculation of Minimum Tax", does not permit the taxpayer to adjust the net capital losses applied for the purpose of calculating minimum tax to the extent that those losses occurred before 1986.  ... It is your view that this subparagraph of the Act would limit the taxpayer's application of net capital losses for the purpose of Division E.1 to the lessor of; a)     24(1) the amount which in your view can reasonably be considered to be the amount the taxpayer would have deducted under paragraph 111(1)(b) has paragraph 127.52(1)(d) been applicable in computing that amount, and b)     24(1) the amount which in your view would otherwise be notionally deductible by the taxpayer had paragraph 11(8)(a) of the Act been computed without reference to any fraction for a taxation year commencing after 1985. ...

22 September 1993 Administrative Letter 9327046 F- Business Expense Unedited CRA Tags 18(1)(a) Client Assistance Directorate Financial Industries H.K.Beauchemin Division Director General Attention:  Rick Owen Corporate Deductibility of Costs for Cardio-Pulmonary Resuscitation (CPR) Courses Further to our telephone conversation(Owen/Shea-DesRosiers) of September 21, 1993, concerning our reply of September 13, 1993 to your memorandum of June 9, 1993 on the above-subject (our file 7-931720), we have the following comments in response to your queries: 1.      ... It is not limited to a particular number or group. 2.     In the last paragraph of our letter, the reimbursement of the cost of the course to the employee by the employer would be deductible to the employer pursuant to paragraph 18(1)(a) of the Income Tax Act (see Interpretation Bulletin IT-357R2, number 7). ...

27 February 1990 Administrative Letter 90M02506 F- Security of Budget Related Documents Unedited CRA Tags n/a   February 27, 1990 Mr. ... Joy (957-2083)   File No. 90M02506 Security of Budget Related Documents Further to recent discussions between your Directorate and this Division, we were advised that we should have a shredder in this Division for destruction of documents related to Budget proposals once those documents are no longer required.  ...