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1 August 1989 Ministerial Correspondence 20184 F- Tax Remission Request Unedited CRA Tags n/a   August 1, 1989 Enquiries and Taxpayer Assistance Technical Interpretations Division Division   P.K. ... Francine Ouellette 957-9229   File No. 2-0184 SUBJECT:  19(1) Further to our telephone conversation with your Ms Francine Ouellette of July 31, 1989, we are forwarding herewith a request for tax remission received recently from our Sudbury Taxation Centre. ...

You have provided us with the following scenario: (a)     Company A, a resident of Canada, forms AB Joint Venture with Company B, a resident of the U.K.. (b)     AB Joint Venture enters into a contract to provide certain services to Company X during the development of the offshore oil fields. ... b)     Would the "non-resident" be qualified to make instalment payments, if any are required, commencing with the second year of operation of the joint venture? ...

4 October 1990 Ministerial Correspondence 51154 F- Tenant Improvement and Acquisition Allowance Received by Partnership Unedited CRA Tags 96(1), 13(7.4), 53(2.0), 53(2.1), 12(1)(x), 9(1) 24(1) 5-1154   R. ... If amounts received have not already reduced the cost or capital cost under other provisions of the Act then paragraph 12(1)(x) will apply to include applicable amounts in income unless one of the other exemptions in paragraph 12(1)(x) applies. 3.      ... Subsection 53(2.1) allows taxpayers to elect to reduce the cost of any non-depreciable property by the amount of any related amount received which would otherwise be included in income by virtue of paragraph 12(1)(x). 5.      ...

9 February 1990 Ministerial Correspondence 74364 F- Travelling Expenses for Tree Planters Unedited CRA Tags 8(1)(h), 8(4)   February 9, 1990 Assessing and Enquiries Specialty Rulings Directorate Directorate Personal and General Section   S. ... For those taxpayers that do qualify to' deduct travelling expenses under paragraph 8(1)(h) of the Act, we offer the following comments and suggestions to your specific queries: 1.      ... We do, however, refer you to our comments following 4. 3.     There is no requirement that an employee travel continuously from job site to job site for expenses to be deductible.  ...

5 April 1990 Ministerial Correspondence 74754 F- Leave of Absence Plans Unedited CRA Tags 6801(a) 19(1) File No. 7-4754   D.S. ... We suggest that the following information be included in the Plans: 4.      ... Accordingly, form T4 should be used by the 24(1) to report the earnings and the usual tax withholdings and remittances must be made. 5.      ...

En vertu du paragraphe 118.2(1), la fraction déductible des frais médicaux admissibles demandés est la partie de ces frais qui excède le moins élevé des deux montants suivants: la somme de 1 962 $ pour l'année 2008 ou 3 % du revenu net du particulier pour l'année. On multiplie ensuite la fraction déductible des frais par le taux d'imposition le plus bas pour l'année, 15 % pour 2008, pour en arriver au crédit d'impôt pour frais médicaux. ... L'expression " appareil de prothèse auditive " comprend les piles nécessaires au fonctionnement de l'appareil et les réparations de celui-ci. ...

14 August 1990 Ministerial Correspondence 59544 F- Supplemental Pension Arrangement Unedited CRA Tags 6(1)(a), 12(1)(n.3), 20(1)(r), 56(2) 248(1) retirement compensation arrangement, 248(1) salary deferral arrangement 24(1) 5-9544   W.C. Harding   (613) 957-8953 Attention: 19(1) August 14, 1990 Dear Sirs: This is in reply to your letter dated February 6, 1990 in which you requested a technical interpretation with respect to the following situation. ... In our opinion, the following additional tax consequences will result in the described circumstances: 1.      ...

The fact that a loan is received by an officer or employee or his spouse or by an individual who is to become an officer or employee or his spouse, from a party other than his employer is not necessarily indicative that such loan has not been received by virtue of an office or employment, the Department will take into consideration any involvement or assistance by his employer in obtaining the loan, including (a)     involvement in negotiation of the loan. (b)     guaranteeing repayment of the loan principal or interest, (c)     recommending in writing to the lender that the loan be made, (d)     agreement in writing before the loan is made, to assist   with the cost of the interest  either by direct reimbursement tot he borrower for all or part of it or by paying such interest directly to the third party lender, or (e)     providing the individual with a letter of introduction  to a mortgage lender explaining the amount and terms of   the mortgage interest subsidy which the employer will be  making to the employee. ...

Our comments are as follows: 1.     Paragraph 98(1)(c) requires that a deemed gain on the disposition of a partnership interest is to be determined as at the end of the partnership's fiscal period. 2.      ... (See paragraph 9 of Interpretation Bulletin, IT-358 where distribution of all the partnership's assets occurs more than twelve months after it actually ceases to exist). 3.      ... In such a case, the winding-up of the partnership automatically brings the fiscal period to an end. 4.      ...

17 October 1990 Ministerial Correspondence 901534 F- Transfer of Retiring Allowances Unedited CRA Tags 60(j.1), 248(1) registered pension plan 24(1) 901534   M.P. Sarazin   (613) 957-2125 October 17, 1990 Dear Sirs: We are writing in response to your letter dated July 6, 1990 wherein you requested a technical interpretation of the application of subsection 60(j.1) of the Income Tax Act (Canada) (the "Act") in the following situation. Facts 1.     Opco is a Canadian corporation. Opco is under an obligation to pay its employees retiring allowances in certain circumstances in consideration of long-term services rendered to the company. 2.      ...