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23 October 1989 Income Tax Severed Letter AC73632- Foreign Retirement Arrangement Date: October 93. 1989 TO: Assessing & Enquiries Directorate FROM: Financial Industries Division P. ...

XXXX is of the opposite view. 2) Your interpretation of the last sentence of paragraph 5 of Interpretation Bulletin 479R which reads in part "... which sells such investment from time to time. ...

24 October 1989 Income Tax Severed Letter AC74312- Employee's Profit Sharing Plan Registration Directorate Rulings Directorate Registered Pension & Deferred Financial Industries Division Income Plans Division W.C. ...

Paragraph 18(1)(m) provides that "... no deduction shall be made in respect of... any amount... paid or payable by virtue of an obligation imposed by statute... to (i) Her Majesty in right of... a province, (ii) an agent of Her Majesty in right of... a province, or (iii) a corporation, commission or association that is controlled by Her Majesty in right of.. a province or by an agent of Her Majesty in right of.. a province as a royalty, tax..., lease rental or bonus or as an amount, however, described, that may reasonably be regarded as being in lieu of any such amount, and that may reasonably be regarded as being in relation to (iv) the acquisition, development or ownership of a Canadian resource property, or (v) the production in Canada of... ...

MORPHY Chief Services, Public Utilities & Exempt Corporations Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch ...

In contrast, the response to the direct request to define "operating costs" as reported in the Commons Debates of March 10, 1983 was "... this includes gasoline, repairs, insurance and other charges that would be applied against the vehicle to keep it on the road"; a statement which could be used to support the Department's position. ...

Le paragraphe 2d) du bulletin d'interpretation IT-487 stipule que notre interprétation du passage "... de l'entreprise... ...

Bowen 19(1) (613) 957-2096 January 22, 1990 Dear Sirs: Re: Active Business Income We are writing in reply to your letter of July 26, 1989, wherein you requested our interpretation concerning the "flow through " of active business income to a limited partner for the purposes of sections 125 and 95 of the Income Tax Act (the "Act"). ...

Yours truly, for Director Services, Public Utilities & Exempt Corporations Section Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

George Wimpey & Co. Ltd, 1953, All E.R. 583, affd. 1953 All E.R. 915 C.A). ...