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AC745337 F- Registered Retirement Savings Plans Proceeds to Death Unedited CRA Tags 146(8.8)     7-4533 19(1) W.C. Harding   613-957-3499 January 26, 1990 Dear Sir: Re:  Registered Retirement Savings Plans (RRSPs) Proceeds on death This is in reply to you letter of September 29, 1989 in respect of the above-noted topic which was referred to us for reply by our Assessing and Enquiries Directorate. ...

HBW40002/4125S7 (E) F- Canada-Sweden Income Tax Convention on Pensions Unedited CRA Tags n/a 19(1) Jim Wilson   (613) 957-2063   HBW 4000-2   HBW 4125-S7 March 23, 1990 19(1) We are writing in reply to your letter dated March 15, 1990, concerning the tax treatment of certain pensions received from Sweden. ...

10 September 1990 Internal T.I. 901289 F- Deductibility of Expenses Against Employment Income Unedited CRA Tags 8(1)(h) 19(1) 901289   J. Szeszycki   (613) 957-2103   EACC9668 September 10, 1990 19(1) Re:  Deductible of Expenses Against Employment Income This is in reply to your letter dated April, 1990 concerning the deductibility of certain types of expenses incurred by individuals doing work for your 24(1)  We apologize for the delay in providing our response. ...

HBW40003/4125I7 (E) F- Canada-Italy Income Tax Convention- Quebec Pension Plan Benefits Unedited CRA Tags n/a 19(1) HBW 4000-3   HBW 4125-I7   Jim Wilson   (613) 957-2063 March 1, 1990 19(1) We are writing in reply to your letter dated February 1, 1990, concerning the tax treatment in Italy of benefits received from the Quebec Pension Plan. ...

Day   and Collections                       (613) 957-2136                                           File No. 911437 SUBJECT:  19(1) Application of ITAR 19 24(1) Further to our telephone conversation of June 3, 1991, we are forwarding a copy of the request for an advance income tax ruling dated May 3,1991 submitted on this taxpayer's behalf by 24(1) 24(1) He will, in due course, be forwarding copies of the LTD plan plus any amendments thereto, for your determination as to whether the plan qualifies as an exempt plan or an amended plan as discussed in IT-428. ...

HBW 6591-I4-/4125I7 (E) F- Canada-Italy Income Tax Convention- Interest Income Exemption Unedited CRA Tags n/a 19(1) Jim Wilson   (613) 957-2063   HBW 6591-I-4   HBW 4125-I-7 February 15, 1990 Dear 19(1) Re:  Special Section for 24(1) We are writing in follow-up to our telephone conversation on February 13, 1990, in which you requested confirmation as to the status of the above-noted institution under Article XI of the Canada- Italy Income Tax Convention. ...

19 September 1990 Internal T.I. 900757 F- Payment of Membership Fees by Employers Unedited CRA Tags 6 19(1) 900757   R.B. Day   (613) 957-2136   EACC9646 September 19, 1990 19(1) Re:  Payment of Membership Fees by Employers This is in reply to your letter of May 7, 1990, wherein you requested our opinion on the income tax implications where membership fees are paid by an employer on behalf of an employee. ...

13 December 1989 Internal T.I. 32799- Demande de décisions anticipées Unedited CRA Tags n/a   19(1) 19(1) 3-2799   C. Thériault   (613) 957-8978 Le 13 décembre 1989 Madame, OBJET:  24(1) Demande de décisions anticipées La présente fait suite à votre lettre du 1er décembre 1989, relativement à votre demande de décisions anticipées du 8 novembre 1989 pour le compte du contribuable mentionné plus haut, dans laquelle vous exprimez le désir de retirer cette demande.  ...

Y has the following income and expenses: • Wages for services performed in the U.S. $12,400 • Dividend income from sources within the U.S. $3,000 • Wages for services performed in Canada $100,000 • Interest income from sources in Canada $1,000 • Dividend income from sources in Canada $4,000 Gross income $120,400 • Un-reimbursed employment expenses-- $3,400 of which $1,000 were attributable to wages earned in the U.S. and $2,400 were attributable to wages earned in Canada • Interest on home mortgage in Canada-- $2,900 • Real estate tax-- $940 • Charitable contribution-- $480 • Personal exemption-- $2,500 Mr. ... To determine the net employment income from sources in the U.S., we need to calculate the expenses and deductions allocated to such income as follows: • Allowable employee expense deduction allocated to U.S. wages $1,000 x $712 = $ 414 $1,720 • Interest on home mortgage* $12,400 x $2,900 = 713 $50,400* • Real estate tax and charitable contribution** $12,400 x ($940 + $480) = 146 120,400** $1,273 Therefore, MR. ... Y's net dividend income from sources in the U.S., we need to calculate the allowable itemized deductions allocated to such income as follows: • Interest on home mortgage $ 3,000 x $2,900 = $ 173 $50,400 • Real estate tax and charitable contribution $ 3,000 x ($940 + $480) = 35 $120,400 $ 208 Therefore, Mr. ...

However, the known values are A = $106,000, C = nil and D = $106,000. ... We agree with your calculation of the deduction under subsection 146.3(6.2) of the Act as set out in your e-mail and explain it as follows: (B + C- D) A x (1- (B + C)) where A = (a) $106,000 + (b) $7,700 (Tax-paid amount (if RRIF were an RRSP and definition of "tax-paid amount" in subsection 146(1) applied) received by individual who received "designated benefits") + (c) nil = $113,700. B = Nil (Fair market value of RRIF at the later of (a) December 31, 1995 and (b) November 10, 1997- the time immediately after the distribution to the spouse of the designated benefits) C = $113,700 (Total of all amounts paid out of the RRIF after the death of the annuitant) D = $100,000 (Lesser of (a) FMV at time of death of annuitant and (b) the sum of B and C). ...