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28 March 1990 Administrative Letter F3421 F- Block Averaging and Minimum Tax Unedited CRA Tags n/a   March 28, 1990 Mr. ... Burnett   (957-2078)   File No. F-3421/3576 Block Averaging and Minimum Tax This is in response to your memoranda of November 21, 1990 and March 5, 1990 concerning the above subject. ...

14 August 1990 Administrative Letter 901266 F- Worker's Compensation Payments Unedited CRA Tags n/a   August 14, 1990 Source Deductions Division Business and General Mr. ... Jones 957-2104   901266   EACC9317 SUBJECT: Worker's Compensation Payments This is in reply to your memorandum of June 13, 1990 concerning payments made by an employer to an employee pursuant to an agreement between the employer and a Worker's Compensation Board to provide vocational or on-the job training for an injured employee. ...

1 August 1990 Administrative Letter 900556 F- Prescribed Premium in respect of an Interest in a Life Insurance Policy Unedited CRA Tags 12.2(9), 309 24(1) 900556   J.P. Dunn   (613) 957-8953   EACC9361 Attention: 19(1) August 1, 1990 19(1) We are writing in response to your correspondence of April 23, 1990 regarding the application of subsection 12.2(9) of the Income Tax Act (the "Act") to a certain hypothetical situation. ...

18 June 1990 Administrative Letter 58966 F- Canada-Australia Income Tax Convention Unedited CRA Tags n/a 24(1) File No. 5-8966   G. Arsenault   (613) 957-2126 Attention: 19(1) June 18, 1990 Dear Sirs: This is in reply to your letter of October 2, 1989 wherein you requested our opinion on the interpretation of Article 21 of the Canada-Australia Income Tax Convention (1980) (the "Treaty") in the following hypothetical situation: (a)     Canco, a Canadian private company carries on business in Canada; (b)     Aco, an Australian company, holds 100% of shares of Canco; (c)     Aco, which does not carry on business in Canada, disposes of the shares in Canco to USCo, a U.S. company, and capital  gain is generated from the disposition; (d)     The contract of sale is initiated, negotiated and concluded  outside of Canada. ...

1 May 1992 Administrative Letter 9206506 F- Application Of The 50% Test And"Liable To Pay Tax"(4232) Unedited CRA Tags 110(1)(f)(i), 217   May 1,1992 Assessment & Accounting     K.B. ... B.     In calculating the total amount that would be liable to tax under Part XIII of the Act, you questioned whether treaty exempt income (e.g. Old Age Security, Canada or Quebec Pension Plan benefits and alimony paid to a U.S. resident) would be included in the phrase "... liable to pay tax under Part XIII... ...

25 September 1992 Administrative Letter 9227446 F- Benefit Accrual Rate For Defined Benefit RPP Unedited CRA Tags ITR 8503(3)(g)   7-922744   D. Duff   957-8953 September 25, 1992 Registered Plans DivisionFinancial Industries DivisionTechnical Review SectionDeferred Income Plans Section Attention:  John O'Meara The 2% limit in paragraph 8503(3)(g) This is in response to your memorandum of September 21, 1992 regarding the interpretation of the 2% maximum on the benefit accrual rate in paragraph 8503(3)(g) of the Income Tax Regulations. ...

8 June 1990 Administrative Letter 900936 F- Election Re Partial Shareholding of Corporation Unedited CRA Tags 70(5), 70(6), 70(6.2), 248(1) property 24(1) ROUND TABLE- JUNE 1990   900936   Don Sommerfeldt Question 11 May an election under subsection 70(6.2) be made with respect to a partial shareholding of a corporation?  ...

(ii)     when a farmer resides and operates a farm outside a prescribed drought region and also maintains a breeding herd in a prescribed drought region where the herd is cared for under a lease arrangement. (iii)     when a farmer resides and operates a farm in one area and during the summer months relocates his breeding herd to a community pasture if either the farmer's own pasture or the community pasture becomes a prescribed drought region. ... (iii)      As outlined above, to be eligible for a deduction pursuant to subsection 80.3(4) of the Act, the breeding herd must be part of a farming business that was carried on at any time during the taxation year in a region that is a prescribed drought region at any time in the year. ...

28 November 1989 Administrative Letter 59046 F- Reply to Letter Unedited CRA Tags n/a 19(1) File No. 5-9046   Maureen Shea-DesRosierss   (613) 957-8953 November 28, 1989 Dear Sir: This is in reply to your letter of August 28, 1989 which was forwarded to us by the Taxpayer Assistance Division. ...

20 December 1989 Administrative Letter 32686 F- Request for Advance Income Tax Ruling Withdrawn Unedited CRA Tags n/a 19(1) 3-2686   D. Watson   (613) 957-2121 December 20, 1989 Dear Sirs: Re:  19(1) In response to your letter of November 30, 1989 we acknowledge the withdrawal of your request for an advance income tax ruling on behalf of the above taxpayer. ...