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Miscellaneous severed letter

23 October 1989 Income Tax Severed Letter RCT 7-4195

The following definitions are set out by Sloan and Zurcher in A Dictionary of Economics (4th ed) (New York: Barnes & Noble, Inc., 1968, at p. 34) A registered bond is recorded in the name of the owner. ... John Wiley & Sons: New York, 1978, at p. 375 a bond that is entered on the books of the issuing company in the name of the owner. ...
Miscellaneous severed letter

25 April 1990 Income Tax Severed Letter RCT-0155

Aucun limite a la duree d'une position a decouvert Il n'y a pas de limite quant a la duree d'une position a decouvert tant que le courtier du vendeur peut emprunter une quantite equivalente de titres vendus a decouvert et que le vendeur maintient une couverture suffisante dans son compte a decouvert. (...) 5. ... No limit on duration of a short position There is no limit on the duration of a short position as long as the seller's broker can borrow an equivalent quantity of securities sold short and the seller maintains sufficient coverage in his short selling account. (...) 5. ...
Miscellaneous severed letter

7 July 1996 Income Tax Severed Letter 9608843 - Distress preferred shares

PRINCIPAL ISSUES: % ownership and amount being financed by DPS. POSITION: Give rulings. REASONS: Only % holding of debt being refinanced. XXXXXXXXXX XXXXXXXXXX 960884 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1996 Dear Sirs: Re: XXXXXXXXXX We are writing in response to your letter dated XXXXXXXXXX wherein you requested an advance income ruling on behalf of the above-noted taxpayers. ...
Miscellaneous severed letter

7 April 1991 Income Tax Severed Letter - Sale of Accounts Receivable, Inventory and Future Obligations - Transfer of Contingent Reserves

On page 5223 of the case, the court acknowledged that "... in the case of the purchase of a business as a going concern,... the expenditure (if it is not clearly for the purchase of stock in trade) is always a capital expenditure... ... These cases include Ross & Day, [[1976] C.T.C. 707] 76 DTC 6433 (FCA), Transport Direct Systems, [[1984] C.T.C. 2845] 84 DTC 1773 (TCC), Burnco Industries Ltd., [[1984] C.T.C. 337] 84 DTC 6348 (FCA), Harlequin Enterprises Limited, [[1977] C.T.C. 208] 77 DTC 5164 (FCA), and Amesbury Distributors Limited, [[1984] C.T.C. 667] 85 DTC 5076 (FCTD). ...
Miscellaneous severed letter

25 April 1990 Income Tax Severed Letter

Il n'y a pas de limite quant à la durée d'une position à découvert tant que le courtier du vendeur peut emprunter une quantité équivalente de titres vendus à découvert et que le vendeur maintient une couverture suffisante dans son compte à découvert. [...] 5. ... No limit on duration of a short position There is no limit on the duration of a short position as long as the seller's broker can borrow an equivalent quantity of securities sold short and the seller maintains sufficient coverage in his short selling account. [...] 5. ...
Miscellaneous severed letter

14 June 1990 Income Tax Severed Letter

14 June 1990 Income Tax Severed Letter 14 June 1990 TO Appeals Branch Appeals & Referrals Division FROM Scientific Research Audit Applications Audit Programs Directorate R.P.Laramy 952-0605 Attention: J.E.Nordin SUBJECT: Current Expenditures of Sole-Purpose Scientific Research and Experimental Development (SR&ED) Corporations We are writing in reply to your memorandum which dealt with expenditures incurred by sole-purpose SR&ED companies. ... Advertising and selling expenses which constitute general administration and management expenses- Regulation 2902 (a) (i) (D) & (E) expenditures In our view, advertising and selling expenses that fall into this category would relate specifically to promoting the business of performing SR&ED, rather than promoting the product or process that is developed as a result of the SR&ED. ...
Miscellaneous severed letter

25 April 1990 Income Tax Severed Letter ACC9152 - Short Selling ("Ventes a découvert")

Il n'y a pas de limite quant à la durée d'une position découvert tant que le courtier du vendeur peut emprunter une quantité équivalente de titres vendus à découvert et que le vendeur maintient une couverture suffisante dans son compte découvert. {...) 5. ... No limit on duration of a short position There is no limit on the duration of a short position as long as the seller's broker can borrow an equivalent quantity of securities sold short and the seller maintains sufficient coverage in his short selling account. {...} 5. ...
Miscellaneous severed letter

7 July 1988 Income Tax Severed Letter RCT-0001 F

., for example, plainly says "... it makes no real difference in substance or as to the nature of the payments whether they arise through a "reservation", strictly so called, or a covenant. ... Commissioners of Inland Revenue, "the fact that people who, after all, now all about it, choose in their agreement to refer to these annual sums *** as "royalties", is a matter not to be entirely neglected". ... Gregory & Co. 196 1 Q. B., 147; B. L. Grain Ltd. v. Ashton et al (1949) or 303). ...
Miscellaneous severed letter

30 November 1999 Income Tax Severed Letter 9M19160 - QUE. REGION TECH. ADVISORS CONF.

Total compensation received: $1,500,000 Compensation for land and building: $1,200,000 Compensation for moving equipment: $ 300,000 Is the equipment considered to have been expropriated? ... Paragraph 20 mentions that "The compensation award determined by the expropriating authority may take into account, in addition to the fair market value of any expropriated property, several other factors such as: (...) costs of relocation, including moving costs (...) may form part of the proceeds of disposition of the property disposed of. ... "...for the purpose of gaining or producing income from the business or property ". ...
Miscellaneous severed letter

24 February 1992 Income Tax Severed Letter 9206085 - 1992 Manitoba Canadian Bar Association/CICA Roundtable

Department's Position The wording of paragraph 60(j.1) refers to "an employer" and in clause 60(j.1)(ii)(a) to "... years... employed by the employer or a person related to the employer... ... Although the Act does not provide for a designation to be filed after a return of income has been filed for a particular taxation year, the Department is prepared to consider a reassessment of only the excess (deemed proceeds over safe income) if all of the following conditions are met: the client made a reasonable attempt to calculate the safe income amount at the beginning of the series of transactions,-the transaction has been reported,- the residual amount (the excess of the proceeds over the client,s safe income) has been reported as a capital gain in the client's return of income when filed, and- the client requests in writing that the Department reassess only the excess. ...

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