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Paragraph 5 (i)       We suggest that the first sentence be deleted and replaced with:      Opco derives its income from a small manufacturing business. (ii)      We suggest that you delete the sentence "The Building is Opco's only asset of Class 3 of Schedule II to the Income Tax Regulations".       ... Paragraph 6 (i)      We suggest that the words "distributor of electrical appliances" be changed to "distributor of certain products". ...

Paul's 1989 world income consisted of the following amounts all expressed in Canadian currency: 1)     $18,000 salary earned in Canada; 2)     $15,000 salary earned in France; and 3)     $1,000 United States source interest.      Since Paul spent more than 183 days in Canada he will be deemed to be a resident of Canada and will be subject to tax in Canada on his world income ($18,000 + $15,000 + $1,000 = $34,000).  ... You have indicated that non-residents may not claim any non-refundable tax credits unless they meet this test.       ...

Kauppinen   (613) 957-2117 Attention: Thea M. Kreuger   7-4576 SUBJECT:  24(1) This is in reply to your memorandum dated December 6, 1989 wherein you request our opinion regarding the application of subsection 20(12) in the following circumstances. Facts 1.      2.      3.     24(1) 4.      5.      Issue 24(1) Our Opinion 1.      ... Subsection 9(3) states that "income from property" does not include any capital gain from the disposition of that property and "loss from a property" does not include any capital loss from the disposition of that property. 3.      ...

14 May 1990 Administrative Letter 900566 F- Deductibility of Employer Contributions under an RCA Unedited CRA Tags 12(1)(n.3), 20(1)(r), 207.5(1) RCA trust 24(1) File No. 900566   Maureen Shea-DesRosierss   (613) 957-8953 19(1) May 14, 1990 Dear Sirs: Re:  Deductibility of Employer Contributions under a Retirement Compensation Arrangement ("RCA") This is in reply to your letter of April 25, 1990 concerning the above-mentioned subject. You describe the following RCA plan:-      both employees and employer are beneficiaries;-      amounts are to be paid out by the custodian as follows:-      employees would receive 50% of the employer's contribution plus  an amount equal to the 100% of the RCA's income for tax purposes.-      the employer would receive 50% of its contributions.  ...

7 September 1990 Administrative Letter 901756 F- Surplus Strip Unedited CRA Tags 84.1, 112, 245(2) 19(1) 901756   M.P. ... As indicated at pages 50 to 53 of the Technical Notes to a Bill Amending the Income Tax Act and Related Statutes issued by the Honourable Michael Wilson, Minister of Finance, in November 1985,      "Section 84.1 of the Act is an anti-avoidance rule to prevent the removal of taxable corporate surpluses as a tax-free return of capital where there is a non-arm's length transfer of shares by an individual resident in Canada to a corporation....       ... New paragraph 84.1(1)(b) treats the purchaser corporation as having paid a dividend to the transferor where the aggregate of the amount of the increase in the legal paid-up capital of its shares arising as a result of the share transfer and the fair market value of the non-share consideration given by it for the transferred shares  exceeds the total of      (a)  the greater of the adjusted cost base, as modified under new paragraph 84.1(2) (a) or (a.1), to the transferor of the transferred shares and the paid-up capital of the transferred shares, and       (b)  the total paid-up capital reductions required by paragraph 84.1(1)(a) to be made by the purchaser corporation.       ...

THE REGULATIONS Let us first look at the relevant provisions of the Regulations. 1.      ... (See the meaning of "salary or wages" in subsection 248(1) of the Act) 4.      ... " 5.      We would like to draw your attention to an important distinction. ...

The provisions of 20(1)(Z) and 20(1)(Z.1) are merely two exceptions to the general rule. #2.        ... These circumstances do not arise now. #3.       Could this preamble be replaces with the wording of 18(1)(q)? #4.       The key words are "an amount not otherwise deductible".  ...

17 July 1991 Administrative Letter 911293 F- Date of Entitlement to Indian Status Unedited CRA Tags ITR 1102(5), 1100(1)(b)   911293   W. ... Guglich   (613) 957-2102 July 10, 1991 Dear Sirs: Re:      Date of Entitlement to Indian Status pursuant to Bill C-31 In your letter of April 19, 1991, which was addressed to the Department of Finance, you request confirmation of our Department's position regarding the date of an individual's entitlement to Indian status pursuant to Bill C-31. ...

They also advised against tax avoidance, but suggested proper planning of your financial affairs.       ... (5)     19(1) under section 216 of the Canadian Income Tax Act.      QUESTION:  If you return to Canada, you are concerned as to your income tax obligations on your return.  ... E.     Since the house qualifies as taxable Canadian property there will be no deemed acquisition of property when you become a resident of Canada.       ...

24(1)      Accordingly, we advise that the joint venture participants do not have resource profits as defined in Regulation 1204 and as a result do not meet the requirements for the deduction described in paragraph 20(1)(v.1) of the Act and Regulation 1210.      Paragraph 3 of IT-492 defines an industrial mineral as a non-metallic mineral capable of being used in industry, and the word mineral has its ordinary meaning of any chemical or compound occurring naturally as a product of organic processes. 24(1) (2)     Is the joint venture involved in processing activities to qualify the plant for inclusion under Class 29?       ... In view of this statement, we believe the better view is that the joint venture is engaged in the manufacturing or processing of goods for sale and that the plant would be eligible for inclusion in Class 29.       ...