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Ministerial Letter
10 March 1993 Ministerial Letter 9302758 F - Corporate Loss Utilization
10 March 1993 Ministerial Letter 9302758 F- Corporate Loss Utilization Unedited CRA Tags 55(3)(a), ITR 1100 XXXXXXXXXX Dear XXXXXXXXXX I am writing in response to your letter received on January 22, 1993, in which you expressed concerns about an advance income tax ruling referred to in a newspaper article, a copy of which you enclosed. ...
Technical Interpretation - External
27 April 1993 External T.I. 9303045 F - Retirement Compensation Arrangement
27 April 1993 External T.I. 9303045 F- Retirement Compensation Arrangement Unedited CRA Tags 207.5 XXXXXXXXXX Attention: XXXXXXXXXX Dear Sir\Madam: RE: Retirement Compensation Arrangement ("RCA") We are writing in reply to your letter of January 28, 1993, in which you ask several questions concerning the use of letters of credit held by a trustee to fund a RCA. ...
Technical Interpretation - External
6 April 1993 External T.I. 9302825 F - Forgiveness of Debt
6 April 1993 External T.I. 9302825 F- Forgiveness of Debt Unedited CRA Tags 80 XXXXXXXXXX Attention: XXXXXXXXXX Dear Sirs: RE: Debt Forgiveness- Disposition of a Canada Security This is in reply to your correspondence of January 25, 1993 wherein you had requested the views of the Department regarding a situation in which a life insurance company forgives a debt which is, in respect of the life insurer, a "Canada security" as that term is defined in paragraph 138(12)(c) of the Income Tax Act (the "Act"). ...
Technical Interpretation - External
6 April 1993 External T.I. 9304915 F - Employees Profit Sharing Plan
6 April 1993 External T.I. 9304915 F- Employees Profit Sharing Plan Unedited CRA Tags 144(1) employees profit sharing plan XXXXXXXXXX Attention: XXXXXXXXXX Dear Sirs: RE: Employees Profit Sharing Plan This is in response to your letter of February 8, 1993, in which you request the Department's interpretation of the application of subsection 144(1) of the Income Tax Act (the "Act"). ...
Technical Interpretation - External
6 May 1993 External T.I. 9305975 F - Withholding Tax
6 May 1993 External T.I. 9305975 F- Withholding Tax Unedited CRA Tags 153(1)(l), ITR 103(4), ITR 103(6) XXXXXXXXXX Attention: XXXXXXXXXX Dear Sirs: RE: Withholding Tax This is in reply to your letter of February 19, 1993 wherein you requested whether the Income tax Act ("Act") requires a person to withhold tax from lump sum payments out of or under a registered retirement income funds ("RRIF") under certain circumstances. ...
Technical Interpretation - External
28 April 1993 External T.I. 9307485 F - Salary Leave
28 April 1993 External T.I. 9307485 F- Salary Leave Unedited CRA Tags ITR 6801 XXXXXXXXXX Dear Sir: RE: Section 6801 of the Income Tax Regulations (the "Regulations") This is in reply to your undated letter received March 16, 1993 concerning the postponement of a deferred salary leave. ...
Technical Interpretation - External
13 May 1993 External T.I. 9307605 F - Qualified Investment
13 May 1993 External T.I. 9307605 F- Qualified Investment Unedited CRA Tags 146(1) qualified investment, 204 qualified investment XXXXXXXXXX Dear Sir: RE: Qualified Investment for a RRSP This is further to your letter of March 9, 1993, wherein you requested a technical interpretation concerning foreign currency held by a registered retirement savings plan ("RRSP"). ...
Miscellaneous severed letter
4 March 1993 Income Tax Severed Letter 9238675 - Tax Planning
4 March 1993 Income Tax Severed Letter 9238675- Tax Planning Unedited CRA Tags 147.2 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. ... Shea-DesRosiers (613) 957-8953 Attention: XXXXXXXXXX March 4, 1993 Dear Sir/Madam, This is in reply to your letter of December 16, 1992 wherein you request several opinions concerning various proposed situations. ...
Technical Interpretation - External
17 May 1993 External T.I. 9304765 F - Tax Exempt U.S. Pension Fund (4093-U5-100-4)
17 May 1993 External T.I. 9304765 F- Tax Exempt U.S. Pension Fund (4093-U5-100-4) Unedited CRA Tags Treaty U.S. ... Tax Exempt Pension Trust This is in reply to your letter of February 15, 1993 wherein you requested our opinion concerning the residence of a U.S. tax exempt pension trust under the Canada-U.S. ...
Technical Interpretation - External
30 March 1993 External T.I. 9306565 F - Interest on Assumed Debt
30 March 1993 External T.I. 9306565 F- Interest on Assumed Debt Unedited CRA Tags 20(1)(c) XXXXXXXXXX Attention: XXXXXXXXXX Dear Sirs: RE: Deductibility of Interest on Assumed Debt This is in reply to your letter of March 3, 1993, wherein you requested a technical interpretation with respect to the deductibility of interest on assumed debt as reflected in our published positions in the 1992 Corporate Management Tax Conference and the 1992 Canada Tax Foundation Round Table. ...