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20 November 1985 Income Tax Severed Letter RCT 5-8061 F Unedited CRA Tags 85(1), 256(7)(a)(i) Dear Sirs: RE:     Subsection 85(1) and Subparagraph 256(7)(a)(i) of the Income Tax Act This is in reply to your letter of October 8, 1985 wherein you requested certain technical interpretations with respect to the above-referenced provisions of the Act. ...

26 January 1987 Income Tax Severed Letter 95-2684 F RE:     Pension Plan for Employees of the XXX This is in reply to your letter of December 22, 1986, concerning the income tax implications of transferring the actuarially-determined present value of an employee's accrued retirement pension from his plan in Canada to a similar plan in the United States. ...

28 June 1985 Income Tax Severed Letter 9A-1333 F Dear Sirs: RE:     Canada-Netherland Income Tax Convention (the Treaty) This is in reply to your letter of March 28, 1985. ...

7 January 1986 Income Tax Severed Letter 9A-2040 F Dear Sirs: RE:     Canada-U.S. ...

30 April 1986 Income Tax Severed Letter RCT 5-1159 F Unedited CRA Tags 110.6(7), 55(2), 55(3) Dear Sirs: RE:     Subsection 110.6(7) of the Income Tax Act This is in reply to your letter of February 28, 1986 wherein you requested our opinion regarding subsection 110.6(7) of the Income Tax Act (the "Act"). ...

25 January 1980 Income Tax Severed Letter RCT 55-140 F Unedited CRA Tags 55 Dear Sirs: RE:     Your file XXX, Section 55of the Income Tax Act This is in reply to your letter of November 22, 1979 in which you requested an opinion with respect to the effect of section 55 on a hypothetical situation. ...

27 March 1980 Income Tax Severed Letter RCT 5-1314 F Unedited CRA Tags 84.1 Dear Sirs: RE:     Section 84.1 This is in reply to your letter of March 10, 1980 wherein you requested the Department's position as to the applicability of section 84.1 if a taxpayer had acquired shares after 1971 from a person with whom he/she was dealing at arm's length, but had also acquired treasury shares directly from the subject corporation after 1971. ...

22 April 1981 Income Tax Severed Letter RCT 5-2525 F Unedited CRA Tags 73, 85(1)(e.2) Dear XXX: RE:     XXX We reply to your letter dated March 24 concerning the above company. ...

11 April 1986 Income Tax Severed Letter RCT 5-1227 F Unedited CRA Tags 40(1)(a)(ii) Dear XXX: RE:     Capital Dividend Account This is in reply to your letter of March 11, 1986 requesting clarification of the words in the third paragraph of our February 28, 1986 letter that read: "provided no portion thereof is claimed as a reserve at the end of the year". ...

1 November 1985 Income Tax Severed Letter RCT 5-8000 F Unedited CRA Tags 85(1)(e.2) Dear Sirs: RE:     Transfer of Property to a Sister Corporation This is in response to your letter of September 6, 1985 wherein you requested clarification of our position with respect to the application of paragraph 85(1)(e.2) of the Act where a property is transferred between corporations owned by the same shareholder for consideration less than the fair market value of the property transferred. ...