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Administrative Letter
18 January 1990 Administrative Letter 58976 F - Capital Gains Exemption - Qualified Small Business Corporation Share
Opco is owned 100% by Holdco. 4. Opco carries on a business in its own name and also holds investments in Subco 1 and Subco 2. 5. ... The assets of Opco and their fair market value at the present time are as follows: Assets used in active business $950,000 Shares of Subco 1 300,000 Shares of Subco 2 450,000 Term Deposits 350,000 $2,050,000 6. ... Subco 1 carries on an active business and all of its assets are used in the active business at the present time. 7. ...
Administrative Letter
26 March 1990 Administrative Letter 59016 F - Sale of Partnership Interest
26 March 1990 Administrative Letter 59016 F- Sale of Partnership Interest Unedited CRA Tags 1100(17), 1100(16), 1100(15) 19(1) File No. 5-9016 D. ... In your letter you outline the following hypothetical situation in which a partnership interest is sold: 1) Partnership X has a fiscal year-end of December 31. 2) Partnership X carries on the business of renting "leasing property" as that term is defined by subsection 1100(17) of the Income Tax Regulations (the "Regulations"). 3) The sole partners of Partnership X are Corporation A and Corporation B. 4) Corporation A is a "principal leasing business corporation" as defined in subsection 1100(16) of the Regulations. Corporation B is not a "principal leasing business corporation". 5) Corporation C intends to purchase the partnership interest held by Corporation B immediately after Partnership X's December 31, 1989 year-end and upon the commencement of the January 1, 1990 partnership fiscal period. 6) Corporation C is a "principal leasing business corporation". ...
Administrative Letter
24 August 1993 Administrative Letter 9323106 F - Withholding Liability Re Payment by Director to Employee
24 August 1993 Administrative Letter 9323106 F- Withholding Liability Re Payment by Director to Employee Unedited CRA Tags 153, ITR 100, ITR 101 Source Deductions Division Personal and General A. ... Our understanding of the facts are as follows; 1. XXXXXXXXXX 2. ... XXXXXXXXXX 4. Neither the directors nor the committee of employees is registered as an employer with Revenue Canada. ...
Administrative Letter
5 June 1989 Administrative Letter 32386 F - Advance Income Tax Ruling Request Withdrawn
5 June 1989 Administrative Letter 32386 F- Advance Income Tax Ruling Request Withdrawn Unedited CRA Tags n/a 19(1) File No. 3-2386 M.F. Symes (613) 957-2110 June 5, 1989 Dear Sirs: 24(1) We acknowledge our telephone conservation of May 31, 1989 19(1) Symes) in which you indicated that you wished to withdraw your request for an advance income tax ruling dated March 17, 1989, on behalf of the above-noted taxpayers. ...
Administrative Letter
2 November 1989 Administrative Letter 32526 F - Request for Advance Ruling
2 November 1989 Administrative Letter 32526 F- Request for Advance Ruling Unedited CRA Tags n/a 19(1) File No. 32526 Firoz Ahmed (613) 957-2092 November 2, 1989 Dear Sirs: 24(1) Further to our telephone conversation (Ahmed/19(1)) of October 24, 1989 we are writing to confirm that as your request for an advance income tax ruling of June 22, 1989 is being substantially revised, we are unable to proceed on this matter until it is resubmitted. ...
Administrative Letter
26 September 1989 Administrative Letter 32626 F - Advance Income Tax Ruling
26 September 1989 Administrative Letter 32626 F- Advance Income Tax Ruling Unedited CRA Tags n/a 19(1) File No. 3-2626 C.R. Bowen (613) 957-2096 September 26, 1989 Dear Sirs: Re: Advance Income Tax Ruling 24(1) This is to confirm our telephone conversation of September 21, 1989, wherein you withdrew your request for an advance income tax ruling dated August 11, 1989 on behalf of the above-noted taxpayer. ...
Administrative Letter
23 November 1989 Administrative Letter 32456A F - Ruling Withdrawn
23 November 1989 Administrative Letter 32456A F- Ruling Withdrawn Unedited CRA Tags n/a 19(1) File No. 3-2456 A.B. Adler (613) 957-8962 November 23, 1989 Dear Sirs: 24(1) This is in reply to the letter of November 17, 1989 in which 19(1) of your office advised us that your firm was withdrawing the ruling request for 24(1). ...
Administrative Letter
19 July 1989 Administrative Letter 32456 F - Ruling Request Withdrawn
19 July 1989 Administrative Letter 32456 F- Ruling Request Withdrawn Unedited CRA Tags n/a 19(1) File No. 3-2456 A.B. Adler (613) 957-8962 July 19, 1989 Dear Sirs: This is in reply to your letter dated April 28, 1989, and is further to the June 1, 1989 telephone conversation with our Allen Adler, concerning an advance income tax ruling request on behalf of 24(1), 24(1). ...
Administrative Letter
20 July 1989 Administrative Letter 32496 F - Withdrawal of Request
20 July 1989 Administrative Letter 32496 F- Withdrawal of Request Unedited CRA Tags n/a 19(1) File No. 3-2496 Firoz Ahmed (613) 957-2092 July 20, 1989 Dear Sirs: 24(1) We acknowledge our telephone conversation of July 18, 1989 19(1) in which your indicated that you wished to withdraw your request for an advance income tax ruling dated June 6, 1989, on behalf of the above-noted taxpayers. ...
Administrative Letter
27 November 1989 Administrative Letter 32736 F - Advance Income Tax Ruling
27 November 1989 Administrative Letter 32736 F- Advance Income Tax Ruling Unedited CRA Tags n/a 19(1) File No. 3-2736 P. Diguer (613) 957-2120 November 27, 1989 Dear Sirs: 24(1) This is in response to your letter of November 8,1989 wherein you advised us that you wish to withdraw your request for an advance income tax ruling as outlined in your letter to us dated October 3, 1989. ...