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November 20, 2003 XXXXXXXXXX HEADQUARTERS Verification & Enforcement Division Randy Hewlett, B.Comm. ...

August 3, 2004 Charities Directorate Income Tax Rulings Policy & Communications Division Directorate Alison Campbell Attention: Jane Waterfall 957-3496 2004-008018 Donation of Private Corporation Shares to a Private Foundation We are writing in reply to your memorandum of June 3, 2004 requesting our views on several issues related to the donation of the shares of a private corporation to a private foundation by one of five directors of the foundation. ...

Yours truly, Eliza Erskine Acting Manager International Section I International Tax & Trusts Division Policy and Planning Branch ...

Our Comments In our letter of August 21, 1992, we stated that "... a share would be a "prescribed share" (as defined in section 6202.1 of the Regulations) and thereby not a flow-through share, if any of the conditions identified in paragraphs (a)- (f) of the Regulation are met. ...

May 10, 2001 Individual Returns & HEADQUARTERS Processing Directorate Denise Dalphy, LL.B. ...

XXXXXXXXXX states: "... if there were no agreement there would be no potential benefit and this issue would not arise. ...

The Agreement states that the payments of this income were to include "all entitlements you may have under Company policy, common law, as well as any statutory entitlements to notice pay, severance pay, and vacation pay you may have under the Employment Standard Act ". 4. ...

September 13, 2001 Toronto East TSO HEADQUARTERS Small/Med Business Audit Shaun Harkin, CMA Verification & Enforcement (613) 957-9229 Attention: Mike Bolton Trust and Pension Section 2001-008306 XXXXXXXXXX Health and Welfare Trust ("HWT") This is in reply to your memorandum dated May 4, 2001 in which you asked for our comments on the acceptability of the above named trust agreement, which accompanied your letter, as a HWT. ...

Principal Issues: Various issues on sojourning Position: see memo attached Reasons: see memo attached July 9, 2001 International Tax Directorate International Section Rene Fleming, Manager Tim Kuss Policies & Publications Section 957-2117 Policy and Programs Division Attention: Ved Arora 2000-004761 Paragraph 250(1)(a)- Sojourning in Canada You have requested our views with regard to certain issues raised by XXXXXXXXXX, regarding the applicability of paragraph 250(1)(a) to determine the residence status of certain airline pilots employed by a Canadian resident airline. ...

May 17, 2002 Audit Directorate HEADQUARTERS Anne Wilson Wayne Antle, CGA Manager (613) 957-2102 Technical Applications & Valuations Division 2002-013954 Transfer of Professional Income to a Corporation This is further to your email of May 8, 2002, concerning our decision not to revise our position on the transfer of professional income to a professional corporation, despite the decision of the Tax Court in the case of Jerome Wallsten and Lakeside Properties Ltd. v. ...