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20 September 1990 Administrative Letter 901296 F- Corporate-owned Personal-use Real Estate Unedited CRA Tags 15(1), 85(1) 24(1) 901296   L.A. ... The six conditions, all of which must be satisfied in order for the exception to apply, are restated as follows: 1.     the corporation's only objective is the holding of property for the personal use of enjoyment of the shareholder; 2.      ...

. #90026006 Return signed copy to: Technical Review Section Technical Publications Division Room 1016, Cumberland Place   July 25, 1990   EACC9384 19(1) 19(1) I am writing in response to representations made on January 19, 1990 by your member of Parliament, the Honourable Douglas G. ... ReadActing Assistant Deputy MinisterLegislative and IntergovernmentalAffairs Branch c.c.      ... Lewis, P.C, F.C.A., Q.C., M.P., Minister of Transport House of Commons Room 356, Confederation Building Ottawa, Ontario c.c.      ...

6 July 1989 Administrative Letter 74076 F- Pipeline Right of Way and Easement Costs Unedited CRA Tags n/a   July 6, 1989 Mississauga District Office Head Office Appeals Division Resource Industries W 5est Section   Allan B. Nelson Ted Clarke (613) 957-8984   File No. 7-4076 Subject:  24(1) Pipeline Right of Way and Easement Costs Enclosed, as requested in your round trip memorandum dated June 26, 1989, is a copy of our July 4, 1986, reply to Audit's memo dated February 24, 1986, concerning pipeline right of way and easement costs. ...

20 February 1990 Administrative Letter 59486 F- Special Purpose Corporations Unedited CRA Tags 15(1)   February 20, 1990 Vancouver District Office Specialty Rulings Chief of Audit Directorate   P. ... Schneider (613) 957-2123 Audit Review Section   File No. 5-9486 Re:  Special Purpose Corporations This is in reply to your memorandum of January 29, 1990 wherein you requested that we clarify, for a particular taxpayer, the Department's administrative concession with regards to the application of subsection 15(1) of the Act to a particular situation. ...

You describe the following hypothetical situation: 1.     Partnership X has a fiscal year end ending January 31, 1989. 2.      ... A, a partner, leaves the partnership on July 1, 1989. 3.     The partnership determines Mr. A's share of the profits to July 1, 1989, after the financial results for January 31, 1990 are calculated, in March, 1990, and 4.      ...

2 March 1990 Administrative Letter 32886 F- Change of Investment from Interest-Bearing to Interest-Free Unedited CRA Tags 12(3), 12(4), 12(9), 54 disposition, ITR 7000(1)(a) 19(1) File No. 3-2886   Peter Lee   (613) 957-2745 March 2, 1990 Dear Sirs: Re:  Advance Income Tax Ruling Request  24(1) We are writing in reply to your letter of December 11, 1989, wherein you requested an advance income tax ruling with respect to  24(1) We are unable to provide the requested advance income tax ruling because your submission did not include all of the material referred to in paragraphs 3, 6, 14, 15 and 16 of Information Circular 70-6R, which set out the specific submissions for an advance income tax ruling application. ...

31 October 1989 Administrative Letter 58576 F- Transfer of Unused Credit to Spouse Unedited CRA Tags 118(1)(c) 19(1) File No. 5-8576   A. Humenuk   (613) 957-2135 October 31, 1989 Dear Sir: Re:  Transfer of Unused Credits to Spouse We are responding to your letter of August 29, 1989, concerning the transfer of the unused portion of your pension tax credit to your spouse. ...

29 March 1990 Administrative Letter 32926 F- Transfer to Spouse Trust Unedited CRA Tags 70(6) 24(1) File No. 3-2926   J.A Szeszycki   (613) 957-2103 March 29, 1990 Dear Sirs: Re:  Request for Income Tax Ruling We are responding to your letter of December 20, 1989, requesting an advance income tax ruling. ...

21 September 1989 Administrative Letter 58696 F- Paragraph 55(3)(b) of the Act Unedited CRA Tags 55(3)(b), 55(2) 19(1) File No. 5-8696   H.K. Tilak   (613) 957-2122 September 21, 1989 Dear Sirs: Re:  Paragraph 55(3)(b) of the Income Tax Act We are writing in response to your letter of September 13, 1989 requesting the Department's views regarding the circumstances in which a particular liability is considered to relate to a particular asset of a corporation in determining the net fair market value of each type of property for the purposes of a "net" butterfly of the property of that corporation in the course of a reorganization that forms part of a series of transactions or events to which subsection 55(2) of the Income Tax Act (the Act) would, but for paragraph 55(3)(b) of the Act, apply. ...

22 May 1990 Administrative Letter 59226 F- Joint Ventures Unedited CRA Tags n/a 24(1) File No. 5-9226 (900009)   J.D. Brooks   (613) 957-2097 19(1) May 22, 1990 Dear Sirs: Re:  Joint Ventures We are writing in response to your letter of November 1, 1989 in which you requested our opinions regarding the application of the Income Tax Act (the "Act") to joint ventures. ...