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Gauthier, directeur               (613) 957-8982                                                                                                        7-4800Objet: 24(1)   paragraphe 245(2) la LoiFaisant suite à votre rencontre du 27 juin dernier-avec Maurice Bisson de notre division (Bisson\Gauthier\Biscaro), veuillez trouver ci-joint, pour votre information, les documents suivants 7-4800Objet: 24(1)   paragraphe 245(2) la LoiFaisant suite à votre rencontre du 27 juin dernier-avec Maurice Bisson de notre division (Bisson\Gauthier\Biscaro), veuillez trouver ci-joint, pour votre information, les documents suivants   1.       une note de service du 6 mars 1990 gui nous fut adressée par le bureau de district de Montréal (annexe I); 2.       notre réponse à la note de service susmentionnée (annexe II); 3.        ...

As a result, the taxpayer's tax liability on the periodic pension payment is Canadian tax before credit for state income tax ($4,000- $1,500) $2,500 Less: credit for state income tax $ (500) $2,000 U.S. federal tax before foreign tax credit $2,800 Less: U.S. foreign tax credit which is the lesser of $2,500 (Canadian tax before credit for state income tax) and $1,300 (U.S. federal tax of $2,800 less the U.S. source basis tax of $1,500) $1,300 $1,500 California State income tax $ 500 Total $4,000 Example II: Assume the same facts as in Example I except that the U.S. federal income tax on the periodic pension payment is $1,300 instead of $2,800. ... The tax liability of the taxpayer would be: Canadian income tax before credit for excess state income tax ($4,000- $1,500) $2,500 Less: credit for excess state income tax $ (300) $2,200 U.S. federal income tax (since U.S. federal tax is less than U.S. source basis tax, there is no U.S. tax credit in this case $1,300 California State income tax $ 500 Total $4,000 Example III: Assume the same facts as in Example I except that the Canadian income tax on the periodic pension payment is $3,000 instead of $4,000. ... The total tax liability of the taxpayer would be: Canadian income tax before credit for state income tax ($3,000- $1,500) $1,500 Less: Credit for state income tax $ (500) $1,000 U.S. federal income tax before tax credit $2,800 Less: U.S. foreign tax credit which is the lesser of $1,500 (Canadian tax before credit for state income tax) and $1,300 (U.S. federal tax of $2,800 less U.S. source basis tax of $1,500) $1,300 $1,500 California State income tax $ 500 Total $3,000 Issue # 2: Taxable Refund of State Income Tax Another issue is whether U.S. federal income tax on taxable refund of state income tax is creditable for Canadian foreign tax credit purposes. ...

Subsection 126(3) & Subparagraph 110(1)(f)(iii) of the Act Subsection 126(3) of the Act operates similar to the foreign tax credit provisions in that a Canadian resident otherwise taxable on his world income, including his remuneration received as an employee of an international organization, would receive a tax credit against his federal taxes payable in respect of the internal levy (see comments below under "Internal Levy") withheld by the international organization. ... XXXXXXXXXX Foreign Missions and International Organizations Act The FMIO Act has replaced the " Privileges and Immunities (International Organizations) Act ". ... The following is a list of these agencies: Food and Agriculture Organization- FAO General Agreement on Tariffs and Trade- GATT International Atomic Energy Agency- IAEA International Bank for Reconstruction & Development- IBRD (World Bank) International Civil Aviation Organization- ICAO International Development Association- IDA International Finance Corporation- IFC International Fund for Agricultural Development- IFAD International Labour Organization- ILO International Maritime Organization- IMO International Monetary Fund- IMF International Telecommunications Union- ITU United Nations Educational, Scientific & Cultural Organization- UNESCO (included are International Institute for Educational Planning, International Bureau of Education and Intergovernmental Committee for Physical Education and Sport) United Nations Industrial Development Organization- UNIDO Universal Postal Union- UPU World Health Organization- WHO World Intellectual Property Organization- WIPO World Meteorological Organization- WMO Note:The above list was prepared by the Provincial and International Relations Division on December 7, 1992. ...

21 December 1989 Income Tax Severed Letter ACC8874 F- Visit by Japanese Officials Unedited CRA Tags n/a   89M12053     December 21, 1989 Pauline McNally Provincial and International Director Relations Division Enquiries & Taxpayer Legislative and Assistance Division Intergovernmental Affairs Branch      E.E. Campbell      (613) 957-2067 VISIT BY JAPANESE OFFICIALS We want to express our tanks for the assistance which you, Joanne Ahearn and Norm O'Donnell gave in meeting with these gentlemen.  ...

LossCo is owned by three arm's length individuals (1/3 share each): Individuals     (A)     (B)     (C)      33 1/3%     33 1/3%     33 1/3% Corporation LossCo 2.      ... Individuals     (A)     (B)     (C)      100%      100%      100% Holding Corp.      A-Co      B-Co      C-Co      33 1/3%     33 1/3%     33 1/3% Loss Corporation LossCo 4.      ...

12 September 1989 Income Tax Severed Letter AC 9086A F- Reporting Requirements for Workers' Compensation Payments Unedited CRA Tags 56(1)(v)     September 12, 1989 19(1) HBW 9086-3   B. Fioravanti   (613) 957-2073 We are writing in reply to your letter of July 21, concerning the reporting requirement of certain compensation received from the Commission. It is our opinion that payments from the Commission for: (a)      Dependency Benefits paid to a surviving spouse; (b)      Death Benefits; (c)      Permanent Functional Impairment Award; (d)      Extended Earnings Loss Benefits; and (e)      Permanent Partial Disability Payment; are to be reported pursuant to paragraph 56(1)(v) of the Income Tax Act as compensation received in respect of an injury, disability or death. ...

1 April 1980 Income Tax Severed Letter Dear Sirs: We would be grateful for your technical interpretation regarding the calculation of foreign accrual property income (FAPI) in the following situation: Beneficiary (resident in Canada)      ] (100%) S94(1)(d) Trust (resident Bahamas)      ] (100%) Investment Holding Co. ...

26 August 1991 Income Tax Severed Letter 911909 F- Gain or Loss Arising on the Disposition of "Exchanged Shares" Unedited CRA Tags 85.1, 245 Dear Sirs: Re:  Section 85.1 of the Income Tax Act This is in reply to your letter dated July 12, 1991 in which you requested: (i)     our interpretation of the phrase "any portion of the gain or loss" in paragraph 85.1(1)(a) of the Income Tax Act (the "Act), and (ii)     our views regarding the application of sections 85.1 and 245 of the Act to the hypothetical series of transactions described below. Facts and Hypothetical Series of Transactions 1.      24(1) 2.      3.      4.                       24(1) Our Comments The situation outlined in your letter appears to relate to specific proposed transactions with identifiable taxpayers.  ... This paragraph states:     "Where a vendor receives shares for some of the exchanged shares and cash or other consideration for other exchanged shares, subsection 85.1(1) may be utilized in respect of the exchanged shares for which shares were received, as long as the vendor can clearly identify which shares were exchanged for cash or other consideration and which (shares) were exchanged for shares. ...

12 December 1989 Income Tax Severed Letter AC8823 F- Employment Status of Families of Diplomats Unedited CRA Tags n/a   89M12280   December 12, 1989 Ms. Cheryl Charette Provincial and International Non-resident Taxation Division Relations Division   Legislative and   Intergovernmental   Affairs Branch      E.E. Campbell     (613) 957-2067 Employment status of families of diplomats and related matters Attached are more notices which External Affairs has sent out to the Embassies and individuals dealing with the employment of family members of diplomats, and other matters related to the mission in Canada. ...

12 April 1991 Income Tax Severed Letter 91-2401T F- Small Business Corporation Unedited CRA Tags n/a Minister/DM's Office                                        YS 91-2401TCentral RecordsAuthorSection ChiefD.O. (?) ...