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Miscellaneous severed letter
25 June 1993 Income Tax Severed Letter 9307055 - Approved Institute
25 June 1993 Income Tax Severed Letter 9307055- Approved Institute Unedited CRA Tags 37(1) 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. ... Brown (613) 957-8954 Attention: XXXXXXXXXX June 25, 1993 Dear Sirs: This is in reply to your facsimile transmission of March 10, 1993 concerning approved organizations and scientific research and experimental development expenditures. ... Brown by telephone June 23, 1993 the Rulings Directorate does not provide written comments on transactions and arrangements which are already in place. ...
Miscellaneous severed letter
28 September 1993 Income Tax Severed Letter 931361A - Partnership—Canada-Egypt Tax Treaty
28 September 1993 Income Tax Severed Letter 931361A- Partnership—Canada-Egypt Tax Treaty Unedited CRA Tags ART 7 96 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. ... Harding (613) 957-2111 September 28, 1993 Dear Madam: Re: Canada-Egypt Income Tax Convention (the "Convention") This is in response to your fax (the "Fax") dated September 22, 1993 concerning the treatment of the income of Canadian partners who are members of an Egyptian partnership which carries on business in Egypt and not in Canada. ... As indicated in our letter of September 14, 1993 the Income Tax Conventions Interpretation Act ("ITCIA"), which was passed in Parliament and received Royal Assent, was enacted to ensure that the interpretation of any of Canada's tax treaties would not prevent Canada from taxing its residents on their world income. ...
Ministerial Letter
24 September 1993 Ministerial Letter 9324478 F - PHSP & Same Sex Issue
24 September 1993 Ministerial Letter 9324478 F- PHSP & Same Sex Issue Unedited CRA Tags 6(1)(a) MINISTER/DM'S OFFICE ADM'S OFFICE RETURN TO RULINGS, ROOM 303, MET. ... For the purposes of the Income Tax Act as it read prior to 1993, the word "spouse" meant persons legally married according to the laws of Canada. Effective with the 1993 taxation year, the meaning of spouse was extended to include a person of the opposite sex with whom the individual cohabits in a conjugal relationship. ...
Technical Interpretation - Internal
23 November 1993 Internal T.I. 9331807 F - Sick Leave Benefits Out of Pension Plan
23 November 1993 Internal T.I. 9331807 F- Sick Leave Benefits Out of Pension Plan Unedited CRA Tags 56(1)(a), 60(j.1), ITR 8503(15) SCARBOROUGH DISTRICT OFFICE HEAD OFFICE G.J. ... Danford (613) 957-8953 BEIA- 451-1-5 933180 XXXXXXXXXX Letter of September 13, 1993 This is in reply to your round trip memorandum of October 27, 1993, in which you asked us to review the above-noted letter and respond to the client's enquiry. ... Enclosed are the original letter and the Routing Slip dated October 13, 1993 from the Winnipeg Taxation Centre. for DirectorFinancial Industries DivisionRulings Directoratec.c. ...
Miscellaneous severed letter
23 November 1993 Income Tax Severed Letter 9328378 - Fairness Legislation
23 November 1993 Income Tax Severed Letter 9328378- Fairness Legislation Unedited CRA Tags 220 164 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. ... RULINGS DIRECTORATE CORRESPONDENCE SUMMARY DOCUMENT TYPE: Minister; Brief; Issue Sheet; PRINCIPAL ISSUES: forgiveness of a loan by employer POSITION TAKEN: benefit taxable REASONS FOR POSITION TAKEN: 6(1)(a) and 6(15) LEGAL: FINANCE OPINION: n/a JURISPRUDENCE: n/a RCT PUBLICATIONS: n/a HAA NUMBER: 7680 Signed: November 23, 1993 XXXXXXXXXX Dear XXXXXXXXXX I am replying to your letter of September 19, 1993, addressed to the Honourable Garth Turner, former Minister of National Revenue, concerning the income tax treatment of a forgiveness of a loan by your former employer. ... Shea-DesRosiers 957-2131 November 8, 1993 ...
Technical Interpretation - External
1993 External T.I. 9336845 F - Farm Support Payments
1993 External T.I. 9336845 F- Farm Support Payments Unedited CRA Tags 12(1)(x), ITR 234 Agriculture and Agrifood Canada Policy Branch Payments, Systems and Procedures 933684 2200 Walkley Road 2nd Floor Ottawa, Ontario K1A 0C5 Attention: Garth McKane January 4, 1994 Dear Mr. McKane: This is in reply to your facsimile of December 16, 1993, requesting our view on whether Tax Information Slips would be required relating to two types of payments to be made to producers in 1994. ... Such premiums paid in 1993 and earlier years would have been treated as an expense in computing farm income in the year of payment. ...
Technical Interpretation - Internal
17 January 1993 Internal T.I. 9336967 F - Indian-Native Fishermen
17 January 1993 Internal T.I. 9336967 F- Indian-Native Fishermen Unedited CRA Tags 81 January 17, 1993 DO/TC Support Services Section HEAD OFFICE R. Cousineau Rulings Directorate Source Deductions Division (613) 957-8953 Native Fisherman This is in reply to your memorandum dated December 17, 1993, requesting our assistance in determining whether certain Unemployment Insurance Benefits (U.I.) received by native fishermen would be exempt from tax. ... As you are aware, U.I. benefits received by Indians are tax exempt if they are based on employment income which itself was exempt, therefore the guidelines issued December 15, 1993 should be applied in determining whether or not the employment income can be connected to a reserve. ...
Technical Interpretation - Internal
1993 Internal T.I. 9320147 F - Taxation of Indian Employment Income
1993 Internal T.I. 9320147 F- Taxation of Indian Employment Income Unedited CRA Tags 81(1)(a) February 3, 1994 EDMONTON DISTRICT OFFICE Head Office E.J. ... Our Comments: As you are aware, the subject of the Section 87 Indian Act exemption was reviewed by the Department following the Williams decision, the result of which was the publication of guidelines on the subject on December 15, 1993. You likely received a copy of these guidelines which were sent to all District Offices by the Taxation Programs Branch on December 20, 1993. ...
Miscellaneous severed letter
28 October 1993 Income Tax Severed Letter 9330630 F - Partie I.3
28 October 1993 Income Tax Severed Letter 9330630 F- Partie I.3 Unedited CRA Tags 181.2(3)(f) 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. ... JURIDIQUE: opinion 7181.2-3(001) du 23 juin 1993 OPINION DE FINANCE: XXXXXXXXXX JURISPRUDENCE: n/a PUBLICATIONS DE REVENU CANADA IMPÔT: n/a DOSSIER SUJET: HAA 5638-3 Table ronde de l'APFF-Colloque "la taxe sur le capital" le 16 novembre 1993 Question 2. ... Ghislain Martineau 28 octobre 1993 5-933063 ...
Miscellaneous severed letter
1 November 1993 Income Tax Severed Letter 9330640 F - Partie I.3
1 November 1993 Income Tax Severed Letter 9330640 F- Partie I.3 Unedited CRA Tags 181(3) 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. ... JURIDIQUE: 7181.2-2(002) du 5 novembre 1993 OPINION DE FINANCE: XXXXXXXXXX JURISPRUDENCE: n/a PUBLICATIONS DE REVENU CANADA IMPÔT: n/a DOSSIER SUJET: HAA 1250-4 HAA 5638-3 Table ronde de l'APFF-Colloque "la taxe sur le capital" le 16 novembre 1993 Question 3. ... Ghislain Martineau 5-933064 1er novembre 1993 ...