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4 December 2003 External T.I. 2003-0041345 - Taxable dividends - loss trust or estate

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch- 1- ...

24 February 2004 External T.I. 2004-0056861E5

. $50,000 @ 20% per year)? Our comments The situation that is described in your letter appears to involve a series of completed transactions involving specific taxpayers. ...

23 February 2004 External T.I. 2003-0051851E5 - S Corporations

Yours truly, Olli Laurikainen Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

25 February 2004 External T.I. 2004-0056681E5 - 164(6) losses and prior tax yrs

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

24 March 2004 External T.I. 2003-0044351E5 - Non-Compete Payments to Non-Residents

., Manager for Director International & Trusts Division Income Tax Rulings Directorate ...

5 April 2004 External T.I. 2003-0050671E5 - attribution of property transferred to a trust

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

30 March 2004 External T.I. 2004-0062291E5 - Discretionary interest in a non-resident trust

Manager for Director International & Trusts Division Income Tax Rulings Directorate ...

28 April 2004 External T.I. 2003-0046241E5 - German tax-exempt life insurance plan

., Manager for Director International & Trusts Division Income Tax Rulings Directorate ...

7 May 2004 External T.I. 2003-0024401E5 - Intervivos transfer of farm property

Subsection 73(3) states, in part, that "... the property was, before the transfer, used principally in the business of farming... ...

9 June 2004 External T.I. 2004-0070381E5 - Amateur Athlete Trusts

" Application of Section 143.1" of the Legal Opinion. Paragraph 143.1(1)(a) provides that where a NSO that is a registered Canadian amateur athletic association ("RCAAA") receives an amount for the benefit of an individual under an arrangement made under rules of an ISF that require amounts to be held, controlled and administered by the NSO in order to preserve the eligibility of the individual to compete in a sporting event sanctioned by the federation, an inter vivos trust (an Amateur Athlete Trust) is deemed to be created on the day that is the later of the day on which the first such amount is received by the NSO, and January 1, 1992, and to exist continuously thereafter until subsection 143.1(3) or (4) applies in respect of the trust. ...

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