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The Queen- Adverse Decision Unedited CRA Tags n/a   September 11, 1990 Appeals and Referrals Division Technical Publications Ms. ... Tremblay Division Director Technical Review Section   Bernhard Buetow Attention: James E. Nordin (613) 957-9226   8-901936      EACC9707 Subject:  Merton Collin v. ...

14 February 1992 Ministerial Letter 9135208 F- Deferred Salary Leave Plan For Teachers Unedited CRA Tags ITR 6802(a)   DM'S OFFICE (2)                                        91-1700D ADM'S OFFICE (3) CENTRAL RECORDS AUTHOR SECTION CHIEF DISTRICT OFFICESubject:OR CORPORATE CASE FILE RETURN TO RULINGS,      ROOM 303, METCALFE BLDG February 14, 1992 19(1) 19(1)      I am writing in response to your letter of December 4, 1991, and further to your telephone conversation of January 7, 1992 (Spice/19(1)), in which you ask whether the Board Regulation entitled "Teacher Funded Leave Plan" (copy enclosed with your letter) satisfies the Income Tax Act requirement that a leave of absence last for a minimum of six consecutive months.        ... I trust my comments will be of assistance to you.      Yours sincerely, Pierre Gravelle, Q.C.c.c.:  Mr. ...

5 September 1989 Ministerial Letter 32608 F- Settlement Unedited CRA Tags 245   September 5, 1989 FILE- Section 245 Small Business and   General Division   P.D. Fuoco   File No. 3-2608 Subject: Advance Income Tax Ruling 19(1) The attached rulings concern a standard structured settlement for which the Department has an established position if the conditions set out in paragraph 5 of IT-365R2 are satisfied. ...

18 September 1990 Ministerial Letter EACC9708 F- Omi Gupta- Adverse Decision of Tax Court Unedited CRA Tags n/a   September 18, 1990 Appeals and Referral Division B. Buetow   Technical Review Section Attention: James E. Nordin Technical Publications   Division   957-9226   EACC9708 Subject:  Omi Gupta Adverse Decision of the Tax Court The taxpayer, a surgeon in Edmonton, reported a capital loss in 1983 on commodity transactions and income losses in 1984 and 1985 on such transactions.  ... BuetowChiefTechnical Review SectionTechnical Publications Division c.c.       ...

19 April 1990 Ministerial Letter 80358 F- Canadian Exploration Expense of a New Mine Unedited CRA Tags 66.1(6)(a)(iii.1)   April 19, 1990 TO Appeals & Referrals Division FROM  Rulings Directorate Appeals Branch Resource Industries   Section Mr. ... Your understanding of subparagraph 66.1(6)(a)(iii.1) both before and after the 1985 amendment is as follows:      "The present wording of subparagraph 66.1(6)(a)(iii.1) is:      "any expense incurred by him after November 16, 1978 for the purpose of bringing a new mine in a mineral resource in Canada into production in reasonable commercial quantities and incurred before the coming into production of the new mine, including..." (emphasis added)      This subparagraph was amended by 1985, c.45, s29(8) applicable with respect to expenses incurred after May 9, 1985.  ...

The corporation is responsible for every aspect of the transportation operation: for example, it has complete control over the following elements: 1)     The ship and its usage; 2)     The nature of the goods to be transported; 3)     The ship's crew.  In this respect, the corporation:  -      can determine the way the ship should be loaded,-      can choose the port agent and stevedores that should be used (the corporation pays for their services);-      can ask for the replacement of the captain if it is not satisfied with his performance; 4)     The place from which the ship will be bunkered and the identity of the supplier, the corporation pays for the bunker; 5)     The place where delivery of the goods is taken; 6)     The destination of the goods; and 7)     The place of taking delivery of the ship at the start of the time charter agreement and the place of redelivery of the ship after the expiration of the charter agreement (within a certain range as determined by the charter agreement). ...

8 March 1990 Ministerial Letter 59638 F- Deemed Year End Where Change of Control Unedited CRA Tags 249(4) 19(1) File No. 5-9638   D. Yuen   (613) 957-2111 March 8, 1990 Dear Sirs: Re: Subsection 249(4) of the Income Tax Act (Canada) (the "Act") We are writing in response to your letter of February 19, 1990 wherein you requested our opinion on the applicability of subsection 249(4) of the Act in the following situation:-      A U.K. company has a wholly-owned Canadian Subsidiary and a branch operation.-      the income earned from the branch operation is subject to tax under Part I of the Act.-      During the year, control of the U.K. company was acquired. ...

You requested our comments related to the following questions: 1.      ... Given the following facts: a)        During a taxation year, the board of directors passes a resolution that certain cash amounts will be used for the prosecution of SR&ED. b)        The cash is invested on a short term basis until it is actually used. c)        All of the cash is eventually used for SR&ED during the year. d)        The interest income received by the corporation in the taxation year from the investment of the funds exceeds the other revenue of the corporation in the year. e)        All or substantially all of the non-interest income of the corporation for the year is derived from the prosecution of SR&ED.       ... Our Comments Our comments related to the above questions are as follows: 1.      ...

30 November 1989 Ministerial Letter 58658 F- Related Persons and the Association of Corporations Unedited CRA Tags 251(2), 252, 256(1) 19(1) File No. 5-8658   A. Humenuk   (613) 957-2135 November 30, 1989 Dear Sirs: Re:  Subsection 251(2) of the Income Tax Act We are replying to your letter of September 6, 1989, concerning related persons and the association of corporations. ... You have also asked whether certain corporations would be associated within the meaning of subsection 256(1) of the Act in the following hypothetical situation: (1)       Brother 1 and Brother 2 own all the shares of Company A. (2)       Each of Brother 1, Brother 2 and Brother 1's son own 20% of the shares of Company B. (3)       An outsider holds the remaining 40% of the shares of Company B. ...

7 November 1990 Ministerial Letter 903108 F- Deductibility of Costs Incurred in Connection with a Takeover Bid Unedited CRA Tags n/a   November 7, 1990 R.K. ... Harms   (613) 957-2109   903108 SUBJECT:  Deductibility of costs incurred in connection with a takeover bid On November 2, 1990, Mr. ... We are therefore telecopying herewith copies of the following: (a)     our memorandum to the Vancouver District Office dated February 16, 1990;      23 (d)     our memorandum to the Vancouver District Office dated October 11, 1990. ...