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11 July 1990 Internal T.I. 90143039 F- Remission of Tax Unedited CRA Tags n/a Minister 90143039 Deputy Minister Central Records Return signed copy to: Technical Review Section Technical Publication Division Room 1016, Cumberland Place 19(1) July 11, 1990   EACC9443 I am writing in reply to your letter of May 2, 1990, concerning your request for remission of tax on behalf of the shareholders of 24(1) Remission request involve an extensive and fully objective review of the facts of the particular situation. ...

23 October 1991 Internal T.I. 912747 F- Former Principal Residence to Rental Property- Ceasing to be a Resident Unedited CRA Tags 13(7)(b), 13(7)(e), 48(1) Dear Sirs: Re:  Application of paragraphs 13(7)(b) 13(7)(e) and 48(1) This is in reply to your letter of September 27, 1991 concerning the application of subparagraphs 13(7)(b) & (e) of the Income Tax Act (the "Act") where a taxpayer after ceasing to be a resident of Canada commences to use his former principal residence as a rental property. ...

For Further Information: Approved by ADM_______ Name: Rick MundellPhone #: 957-2139November 2, 1990 ...

28 May 1990 Internal T.I. 900317 F- Burning Cost Provision Unedited CRA Tags 18(1)(e)   May 28, 1990 Special Audits Division Financial Industries Division E.H. ...

23 April 1990 Internal T.I. 74827 F- Disabled Person's Minimum Wage Protection Act Unedited CRA Tags n/a   April 23, 1990 TO  Provincial and International FROM  J.A. ...

Dubé   957-2065 Attention: 19(1) F-3797 Dear Sir: Re:  Clause 31(8) Technical Amendments- Income Tax Act Draft Legislation- July 13, 1990 This is in reply to your letter dated July 19, 1990 wherein you requested our confirmation of your understanding on the above subject matter in a situation where an arriving immigrant sets up a non-resident discretionary trust and funds the trust with a loan. ...

Since amendments to the Act are the responsibility of the Department of Finance you may wish to contact that Department at the following address:                    L'Esplanade Laurier 140 O'Connor Ottawa, Ontario KlA 1J2 and provide them with the details of your situation.  ...

Albert   (613) 957-2098 19(1) December 6, 1990 Dear Sirs: Re:  Telephone Enquiries From Prospective Investors As you are aware, we have been receiving a number of phone enquiries as a result of the inclusion of a copy of parts of a letter from Revenue Canada to your company in your 24(1). ...

2 November 1989 Internal T.I. 74259 F- Appropriate CCA Class for Ford Ranger Supercabs Unedited CRA Tags 248(1) 74259 (E)   November 2, 1998 Enquiries and Taxpayer J.D. ...

Our comments On XXXXXXXXXX, the definition of TCP in subsection 248(1) read as follows: “‘taxable Canadian property’ of a taxpayer at any time in a taxation year means a property of the taxpayer that is (a) real property situated in Canada, (b) … (c) … (d) a share of the capital stock of a corporation resident in Canada (…) that is not listed on a designated stock exchange, (e) a share of the capital stock of a non-resident corporation that is not listed on a designated stock exchange if, at any particular time during the 60-month period that ends at that time, (i) the fair market value of all of the properties of the corporation each of which was, (A) a taxable Canadian property, (B) … to (E) was greater than 50% of the fair market value of all of its properties, and (ii) more than 50% of the fair market value of the share was derived directly or indirectly from one or any combination of (A) real property situated in Canada, (B) Canadian resource properties, and (C) timber resource properties, … ” (emphasis ours) It is our understanding that, with respect to the shares of the NRCos, the Trust does not dispute that the condition in subparagraph (e)(i) of the definition of TCP was met. ... Moreover, a determination will need to be made of the proportion of the total gross assets of the Subsidiary that comprises of real or immovable property situated in Canada. […] …[A]n amount equal to that same proportion of the FMV of the shares of the Subsidiary will be considered real or immovable property situated in Canada of the Parent in the determination of whether the shares of the Parent derive their value principally from real or immovable property situated in Canada.” ...