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18 June 1992 Administrative Letter 9205286 F- Accrued Interest Unedited CRA Tags 12(4), 212   June 18, 1992 International Tax Programs Directorate Rulings Directorate John Fennelly Financial Industries A/Chief Division F. ... The letter describes a situation whereunder a Canadian resident, who has accrued interest income under subsection 12(4) of Part I of the Income Tax Act (the " Act") subsequently becomes a non-resident and receives the interest previously accrued. ...

Background information, provided by your legal services, gives us the following understanding regarding training trust funds 1.      ... One of the programs was a grant program to provide support for training trust funds (TTFs) 2.      ... It may be established independently or jointly with an employer or group of employers. 3.      ...

The Queen, 90 DTC 6390 (F.C.T.D.), which is under appeal, casts doubt on whether the Supreme Court of Canada's decision in International Iron & Metal Company Ltd. v. ... Dworkin Furs (Pembroke) Ltd. et al [1967] S.C.R. 223, at p. 228:     "[T]he word 'controlled' contemplates the right of control that rests in ownership of such a number of shares as carries with it the right to a majority of the votes in the election of the Board of Directors. ... It is also our view that the case of International Mercantile Factors Ltd., supra, cannot be said to put in doubt the Supreme Court's decision in International Iron & Metal Company Limited, supra.  ...

5 September 1989 Administrative Letter 3206- Version française d'une modification au Réglement de l'impot sur le revenu Unedited CRA Tags n/a   Le 5 septembre 1989 Mr. ... Burnett/ 957-2078   F-3206 Objet: Règlement de l'impôt sur le revenu Par la présente je réponds à votre note de service du 22 août 1989 concernant le sujet ci-dessus. ...

20 March 1990 Administrative Letter 90M03336 F- Ontario Income Tax Act- Foreign Tax Credit Unedited CRA Tags 7(1)(1), 120.1, 121, 122.3   March 20, 1990 Mrs. ... Campbell Ottawa District Office   File No. 90M03336 Ontario Income Tax Act- Foreign Tax Credit In our conversation of March 8 we discussed the calculation of the provincial foreign tax credit on form T2036.  ...

Laurikainen Development of Audit 927-2116 Programs Division Attention: Dave Burton   900740 Deductible Loss- Section 5903 of the Regulations to the Act This is in response to your memorandum dated May 10, 1990 wherein you requested our opinion concerning the computation of a deductible loss under section 5903 of the Regulations to the Act (the " Regulations") for the purposes of subparagraph 95(1)(b)(v) of the Act in a particular audit case. Our understanding of the facts of the case is as follows: 24(1) 24(1) 1)     No amount is determined under any of clause 5907(1)(c)(ii)(A) or subparagraphs 5907(1)(c)(iii) and (iv) of the Regulations for the purposes of subparagraph 5903(1)(b)(i) of the Regulations in respect of a controlled foreign affiliate of an individual. Such amounts are only determined in respect of a foreign affiliate of a corporation. 2)     Even if a deductible loss had been computed for 24(1) in respect of    24(1)     under subparagraph 5903(1)(b)(i) of the Regulations, such losses would not be deductible in computing the FAPI of    24(1)     The active business losses of a foreign affiliate must generally be incurred by the affiliate in respect of the particular taxpayer claiming them. ...

Our understanding of the facts in this case is as follows: XXXXXXXXXX the employer has agreed to reimburse an employee's additional child care costs in certain situations. 1.      ... XXXXXXXXXX 2.     An employee attends a course approved by the employer outside the employee's normal work day such that the employee incurs additional child care expenses. ...

Your correspondence requests a statement addressing the deductibility of moving expenses incurred by instructors on a paid leave of absence to pursue studies at a university located in a city other than   24(1) 24(1)     You have asked that we indicate that a moving expense deduction is available to an individual when the following conditions are met: 1.     the move is necessary to obtain new expertise (and is why the leave is granted by the employer) and 2.      ...

Our understanding of the situation set out in your letter and clarified during our telephone conversation of April 10,1991, is as follows. 24(1) With respect to the pension fund contributions, redirected through the  24(1) of the pension plan, you have analysed the possible income tax consequences for employer pay-all and employee pay-all wage loss replacement plans if the employer 24(1) were to self-fund these pension plan contributions. 1.      ... Because the payment of the plan premiums by the employer does not create a taxable benefit to the employees and since the LTD benefits are taxable in the hands of the recipients, this arrangement would, in your view, have no adverse income tax implications for the employees. 2.      ...

22 September 1993 Administrative Letter 9326116 F- Legal Fees to Secure Wage Loss Benefit From Insurer Unedited CRA Tags 6(1)(f), 8(1)(b)   Client Assistance Directorate Personal and General Hélène Beauchemin Section Director General Attention:  Jeff Shaver Deductibility of Legal Fees Your file: 93-4272T XXXXXXXXXX We are replying to your memorandum of September 8, 1993 in which you ask whether legal fees incurred to re-establish the taxpayer's rights to benefits under a wage loss replacement plan are deductible. As indicated in paragraph 1 of Interpretation Bulletin IT-99R4, legal fees are only deductible to the extent that they a)     are incurred for the purpose of gaining or producing income from a business or property and b)     are not outlays of a capital nature unless such fees are specifically provided for by a provision of the Act. ...