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11 February 1980 Income Tax Severed Letter RCT 89-152 F Unedited CRA Tags 89(1)(c), 248(1) Dear Sir: RE:     Interpretation Bulletin IT-289 dated February 16, 1976 Thank you for your letter of January 25, 1980 in connection with the above-noted interpretation bulletin. ...

16 December 1985 Income Tax Severed Letter RCT 5-7950 F Unedited CRA Tags none Dear Sirs: RE:     Price Adjustment Clauses This is in reply to your letter of August 22, 1985 wherein you requested our opinion regarding the use of a price adjustment clause. ...

16 July 1981 Income Tax Severed Letter RCT 5-2559 F Unedited CRA Tags 85(1), 85(1.1) Dear Sirs: RE:     Transfer of Property to a Corporation by a Shareholder This is in reply to your letter of March 27, 1981 with respect to the transfer of property to a corporation by a shareholder. ...

11 February 1985 Income Tax Severed Letter RCT 5-7269 F Unedited CRA Tags 85(1) Dear Sirs: RE:     Insurers- Application of Subsection 85(1) of the Income Tax Act This is in reply to your letter dated December 11, 1984 wherein you requested our comments concerning the necessity of determining the fair market value of goodwill transferred under the provisions of the above-noted subsection. ...

28 February 1985 Income Tax Severed Letter RCT 55-261 F Unedited CRA Tags 55(2), 55(3)(a) RE:     XXX We have the following comments in respect to the letter of January 9, 1985 from XXX concerning the above-referenced taxpayer. ...

28 August 1985 Income Tax Severed Letter RCT 5-7948 F Unedited CRA Tags 55(5)(f) Dear Sirs: RE:     Paragraph 55(5)(f) of the Income Tax Act This is in reply to your letter of August 28, 1985 wherein you requested our interpretation of the above paragraph when applied to a dividend deemed to have been received by virtue of subsection 84(3) of the Act. ...

24 February 1984 Income Tax Severed Letter RCT 5-5948 F Unedited CRA Tags 55(2) Dear Sirs: RE:     Subsection 55(2) of the Income Tax Act (the "Act") and "Safe Income" This is in reply to your letter of January 20, 1984 in which you asked that we confirm your understanding of our Department's position regarding the calculation of safe income for the purposes of subsection 55(2). ...

5 August 1983 Income Tax Severed Letter RCT 5-5157 F Unedited CRA Tags 88(1)(d.2), 70(5) Dear Sirs: RE:     Paragraph 88(1)(d.2) of the Income Tax Act (the "Act") This is in reply to your letter of June 2, 1983 in which you asked for a technical interpretation of paragraph 88(1)(d.2) of the Act as it relates to an actual fact situation. ...

9 April 1980 Income Tax Severed Letter OS-4301-1 F Unedited CRA Tags 212(1)(b) RE:     Part XIII on Income from Canada of Non-Residents Clause 212(1)(b)(iii)(D)Exception to Chartered Banks Thank you for your letter of March 19, 1980 concerning the above-noted subject matter. ...

13 August 1986 Income Tax Severed Letter 95-1586 F RE:     Subsection 212(5) of the Income Tax Act (the "Act") This is in reply to your letter of May 5, 1986 asking for our confirmation that television programming transmitted by cable constitutes television for purpose of subsection 212(5) of the Act. ...