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Agri-Land Sales & Leasing 900- 1801 Hamilton Street Regina, Saskatchewan 963606 S4P 4L5 A.M. ...

Reasons: Brokerage fees are a cost of acquisition & are added to "cost amount" of securities purchased. ...

Jim Ivey, Section Chief Policy & Technical Services Section Trust Accounts Division?? ...

De façon générale, ces nouvelles exigences prévoient que certains contribuables résidant au Canada et certaines sociétés de personnes seront tenus de produire une déclaration de renseignements relativement à leurs biens étrangers, si le coût indiqué global de ces biens dépasse 100 000 $. ...

Principal Issues: whether payments into an estranged spouse's RRSP are deductible as alimony or maintenance Position: no but they may be deductible as a contribution to a spousal RRSP, subject to the contributor's RRSP room & the monthly tax on any "cumulative excess amount" Reasons: while 60.1(1) may deem the contribution to have been paid for the benefit of the spouse, a payment that is intended to equalize family assets is not on account of maintenance A. ...

In the definition "small business corporation" contained in subsection 248(1) of the Income Tax Act (the "Act") there is a requirement that "... all or substantially all of the fair market value of the assets... are used principally in an active business... ...

Oulton Section Chief Business, Property & Personal Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

In addition, the proposed new taxpayer migration rules, contained in the Notice of Ways & Means released by Finance on October 2, 1996, will apply to deem the individual to dispose of and reacquire the shares of Holdco at fair market value at the time of departure from Canada. ...

Reasons: Persons who have "earned income" (in this case employment income while resident in Canada, and remuneration from employment by non-resident who was previously resident paid by person in Canada & not subject to tax in another country) can contribute to RRSP with limit reduced if participating in an RPP. ...

In this respect we would refer you to paragraph 5 of Interpretation Bulletin IT-218R, which provides: " 5. ...