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Technical Interpretation - External
1993 External T.I. 9333870 F - HAA 7234-1 Look Through Trust Rules
REASONS FOR POSITION TAKEN: Specific wording of the proposed draft legislation released in August 1993. ... Department's Position The proposed amendments to section 259 issued in December 1992 were replaced by draft legislation released in August 1993. ... HARDING FILE: E933387 DATE: DECEMBER 7, 1993 ...
Miscellaneous severed letter
15 December 1993 Income Tax Severed Letter 9334607 F - Remb. de primes—REER
15 December 1993 Income Tax Severed Letter 9334607 F- Remb. de primes—REER Unedited CRA Tags 146(8.1) 146(8) 60l) 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. ... RAISONS POUR POSITION ADOPTÉE: 60l)i) et iv) JURIDIQUE: n/a OPINION DE FINANCE: n/a JURISPRUDENCE: n/a PUBLICATIONS DE REVENU CANADA IMPOT: n/a DOSSIER SUJET: HAA 7255 Le 15 décembre 1993 Centre fiscal de Shawinigan Bureau Principal #334 Direction des décisions (613) 957-8953 Attention: Lola Boucher 5-933460 XXXXXXXXXX XXXXXXXXXX Désignation d'une remboursement de primes d'un régime enregistré d'épargne-retraite ("REER") T2019 La présente fait suite à votre Note de service du 19 novembre 1993 et à votre conversation téléphonique (Aubé/Duval) du 29 novembre 1993 concernant le sujet ci-haut mentionné. ...
Technical Interpretation - External
1993 External T.I. 9331425 F - Gift to Adult Children/Principal Residence
1993 External T.I. 9331425 F- Gift to Adult Children/Principal Residence Unedited CRA Tags 40(2)(b), 40(2)(c), 54 principal residence, 69(1)(b) XXXXXXXXXX 933142 Attention: XXXXXXXXXX December 15, 1993 Dear Sirs: RE: XXXXXXXXXX- Proposed Property Disposal This is in reply to your enquiry dated October 15, 1993, requesting our opinion on the calculation of any taxes resulting from your mother's proposed transfer of property. ... Unfortunately, the 1993 versions of the guides had not yet been issued at the time of writing. ...
Miscellaneous severed letter
15 December 1993 Income Tax Severed Letter 9327366 - Custodian and Information Return
15 December 1993 Income Tax Severed Letter 9327366- Custodian and Information Return Unedited CRA Tags 204(1) 150(1)(c) 150(3) 212(1)(d) 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. ... Mizuik Chief Information Returns Section 932736 Subsection 204(1) of the Income Tax Regulations As discussed in our telephone conversation of December 14, 1993 (Mizuik/Murphy), attached is a memorandum from J.A. ... In a November 16, 1993 letter (the "Letter"), XXXXXXXXXX states that the custodian is not a trustee. ...
Miscellaneous severed letter
28 October 1993 Income Tax Severed Letter 9329598 - Taxation of Indian Employment Income
28 October 1993 Income Tax Severed Letter 9329598- Taxation of Indian Employment Income Unedited CRA Tags 81 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. ... AUTHOR SUBJECT OR CORPORATE CASE FILE October 28, 1993 XXXXXXXXXX Dear XXXXXXXXXX Mr. ... Humphrey 952-0245 October 20, 1993 932959 Y.S. #93-1659 ...
Miscellaneous severed letter
6 October 1993 Income Tax Severed Letter 9319835 - Carryforward of Balances in a Health Care PHSP
6 October 1993 Income Tax Severed Letter 9319835- Carryforward of Balances in a Health Care PHSP 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. ... Humenuk (613) 957-2134 Attention: XXXXXXXXXX October 6, 1993 Dear Sirs: Re: Advance Income Tax Ruling Request XXXXXXXXXX In our telephone conversation of September 22, 1993 (XXXXXXXXXX\Humenuk), you advised that the advance income tax ruling request of July 8, 1993 has been withdrawn. ...
Technical Interpretation - External
29 January 1993 External T.I. 9236665 F - Benefits Resulting From XXXXXXXXXX
29 January 1993 External T.I. 9236665 F- Benefits Resulting From XXXXXXXXXX Unedited CRA Tags 6(1)(a), 6(1)(a)(iv) XXXXXXXXXX Attention: XXXXXXXXXX Dear Sirs: RE: Taxable Benefits XXXXXXXXXX We are responding to your facsimiles of December 9, 1992, and January 15, 1993 wherein you requested our views on the tax implications under paragraph 6(1)(a) of the Income Tax Act (the Act) associated with courses given by your company to prospective clients which involves counselling of their employees on the above subject. We also refer to our telephone conversation of January 15, 1993 (XXXXXXXXXX/Larochelle). The facts regarding your enquiry are as follows: XXXXXXXXXX XXXXXXXXXX Further information on the subject was provided in your facsimile of January 15, 1993 as follows: XXXXXXXXXX Our Comments: As explained in our telephone conversation, we are unable to provide general comments that would apply specifically to all situations as the facts of each case may be different. ...
Miscellaneous severed letter
22 October 1993 Income Tax Severed Letter 932308 - PHSP & Same Sex Issue
22 October 1993 Income Tax Severed Letter 932308- PHSP & Same Sex Issue 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. ... AUTHOR SUBJECT OR CORPORATE CASE FILE October 22, 1993 XXXXXXXXXX Dear XXXXXXXXXX I am writing in reply to your letter of July 27, 1993, concerning the taxation of employer-provided benefits offered to employees. ... Humenuk (957-2134) September 13, 1993 File #932308 ...
Technical Interpretation - External
20 May 1993 External T.I. 9304865 F - Multiple Trusts Settled by a Single Person
20 May 1993 External T.I. 9304865 F- Multiple Trusts Settled by a Single Person Unedited CRA Tags 104(2) XXXXXXXXXX Attention: XXXXXXXXXX Dear Sirs: RE: Subsection 104(2) of the Income Tax Act ("Act") This is in reply to your letter dated February 5, 1993 regarding subsection 104(2) of the Act. ...
Technical Interpretation - External
19 May 1993 External T.I. 9313725 F - Rent Free
19 May 1993 External T.I. 9313725 F- Rent Free Unedited CRA Tags 12(1)(x) XXXXXXXXXX Attention: XXXXXXXXXX Dear Sirs: RE: Lessee- Rent-Free Periods This is in reply to your letter of May 7, 1993, concerning the tax treatment to a lessee during a rent-free period in a lease. ...