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11 June 1992 Income Tax Severed Letter- Forgiveness of loan interest — farmers Unedited CRA Tags 80(1), 80(4) 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. ...

7 May 1991 Income Tax Severed Letter- Foreign affiliates deemed active business income — insurance premiums Unedited CRA Tags 95(2)(a)(ii), Reg. 5907(2)(j) FOREIGN AFFILIATES DEEMED ACTIVE BUSINESS INCOME- INSURANCE PREMIUMS Question Canco is a Canadian corporation that owns 100% of the shares of a foreign affiliate ("FA1") resident in Ireland. ...

7 October 1991 Income Tax Severed Letter- Redeemable, convertible preferred shares — subsection 15(1) benefit Unedited CRA Tags 15(1) REDEEMABLE/CONVERTIBLE PREFERRED SHARES-SUBSECTION 15(1) BENEFIT Question on page 27 A shareholder holds fixed redemption amount preference shares that are convertible into common shares. ...

14 April 1982 Income Tax Severed Letter RRRR83- Non-resident withholding tax exemption — certificates of deposit Unedited CRA Tags 212(1)(b)(iv) XXX This is further to my letter of April 14, 1982 and in reply to your letter of March 10, 1982 concerning the eligibility of Certificates of Deposit for the purposes of the exemption contained in subparagraph 212(1)(b)(iv) of the Income Tax Act (the Act). ...

7 December 1991 Income Tax Severed Letter- Deferred salary leave plan — period of leave of absence Unedited CRA Tags Reg. 6801 Dear XXX Re: Deferred Salary Leave Plan We are writing in reply to your letter of June 7, 1991, to the Kitchener District Taxation Office which was forwarded to us on August 1, 1991. ...

7 March 1991 Income Tax Severed Letter- Leasing transactions — non-resident lessor Unedited CRA Tags none Dear Sirs: Re: Leasing Transactions This is in reply to your letter of January 23, 1991 wherein you requested confirmation that the transaction described in your letter between a Canadian lessee and a non-resident lessor would, although structured as a lease, result in a disposition and acquisition of the property that is the subject of the lease for all purpose of the Income Tax Act (the “Act”). ...

7 May 1991 Income Tax Severed Letter- Capital cost allowance — half year rule on non-arm's length transfers Unedited CRA Tags 85, Reg. 1100(2.2) Question Capital Cost Allowance- Half Year Rule on Non-Arm's Length Transfers A and B are Canadian resident related corporations. ...

18 June 1992 Income Tax Severed Letter- Nikkei index call option — whether qualified investment for registered retirement savings plan Unedited CRA Tags Reg. 4900(1)(e) 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. ...

7 March 1991 Income Tax Severed Letter- Accumulated vacation leave — whether considered retiring allowance Unedited CRA Tags 248(1) Dear Sir: Re: Accumulated Vacation Leave Whether considered Retiring Allowance This is in reply to your letter of November 20, 1990 concerning the above-mentioned subject. ...

7 November 1991 Income Tax Severed Letter- Amortization of pension surplus — income tax treatment to employer Unedited CRA Tags 20(1)(q), 56(1)(a)(i), 147.2(1), 248(1) Subject: Amortization of Pension Surplus Income Tax Treatment to Employer This is in reply to your memorandum of October 24, 1991 concerning the income tax implications where an employer amortizes for accounting purposes, but not for income tax purposes, an actuarial surplus in its pension plan. ...