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28 May 1992 Income Tax Severed Letter 9215965- Two-tiered partnership — active business income Unedited CRA Tags 96(1), 125(7) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

4 November 1996 Income Tax Severed Letter 9632798 F- Politique fiscale — REER Unedited CRA Tags 146 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

24 February 1997 Income Tax Severed Letter 9700015- Article 12 of United Kingdom Convention — videotapes Unedited CRA Tags Canada–U.K. ...

16 February 1998 Income Tax Severed Letter 9802605- Registered retirement income fund minimum amount — fair market value Unedited CRA Tags 146.3(1) SUMMARY: Registered retirement income fund minimum amount- fair market value—ITA-146.3(1)—Determination of fair market value of private corporation shares held within a registered retirement income fund. ...

7 July 1991 Income Tax Severed Letter- Qualified farm property — transfer of partnership farm land to the partners Unedited CRA Tags 98(2), 110.6(2), 110.6(11) Dear Sirs: Re: Qualified Farm Property This is in reply to your letter of May 31, 1991 requesting a technical interpretation with respect to a hypothetical transaction relating to the transfer of partnership farm land to the partners themselves. ...

10 May 1990 Income Tax Severed Letter RRRR443- Interest deductibility — newly incorporated branch Unedited CRA Tags 20(1)(c) xxxxx 5-9052 Peter Lee (613) 957-2745 Attention: xxxxx May 10, 1990 Dear Sirs: Re: Interest Deductibility- Newly Incorporated Branch Operation This is in reply to your letters of November 7, 1989 and March 1, 1990. ...

7 November 1990 Income Tax Severed Letter- Deceased taxpayer — election under subsection 70(6.2); also whether section 54.2 applies to a partnership Unedited CRA Tags 70(6), 70(6.2), 54.2 QUESTION I-100 DECEASED TAXPAYER-ELECTION UNDER SUBSECTION 70(6.2) Subsection 70(6.2) provides that the legal representative of a deceased taxpayer may elect that the provisions of subsection 70(6) do not apply on the death of a taxpayer with respect to any property specified in the election (i.e., you can elect to have the transaction take place at fair market value rather than at tax values). ...

7 October 1991 Income Tax Severed Letter- Canadian controlled private corporation — ownership by a trust Unedited CRA Tags 125(7), 256(5.1) CCPC Status- Ownership by a Trust Question 50 Assume all of the common shares of a private corporation which is incorporated and carries on business in Canada are owned by a trust. ...

4 February 1981 Income Tax Severed Letter RRRR34- Canada-Australia treaty — treatment of capital gains and dividends Unedited CRA Tags 2(3), 115(1)(b), 84, 212.1, Canada–Australia Income Tax Convention Dear XXX This is in reply to your letter of December 29 concerning the Canada-Australia Income Tax Convention (1980) (the Convention) which has yet to be ratified. ...

7 December 1991 Income Tax Severed Letter- Scientific research and experimental development — eligibility of landscaping costs Unedited CRA Tags 37, 20(1)(aa) Dear Sirs: Re: Scientific Research and Experimental Development-Landscaping Costs This is in reply to your letter of July 5, 1991 concerning subsection 37(1) of the Income Tax Act (the "Act"). ...