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Yours truly, Section Chief Leasing & Financing Section Financial Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

McCort, Unit Head Group 1, Unit 1 Enquiries & Office Examination Section Paragraph 53(1)(h) Subsection 18(2)------------------ This is is reply to your memorandum of July 18 concerning interest and property taxes on land which has a vacant building thereon. ...

Generally speaking, the Department's position is that, by virtue of the provisions of paragraphs 3 "... shares... the property of which consists principally of immovable property") and 4 of Article XIII of the Treaty, the taxpayers will not be liable to taxation in Canada on their gain form the disposition of the Holdco shares. ...

Where a van is designed to have two bucket seats in the front and a bench seat in the middle with storage in the back but the bench seat is removed for additional storage, would the van qualify as being "... adapted to carry not more than the driver and 2 passengers... ...

Such an individual must have been "... certified by an appropriately qualified person to be an individual who, by reason of a physical or mental handicap, requires the equipment, facilities or personnel specially provided by the school, institution or other place for the care, or the care and training of individuals suffering from the handicap suffered by that individual... ...

Yours truly, for Director Financial Industries Division Rulings Directorate Legislative & Intergovernmental Affairs Branch ...

In particular, you inquired whether an "open" receivable owing to one corporation (X Co) from another corporation (Y Co) connected with the first corporation would be a "similar obligation " as that expression is used in subparagraph (c)(ii) of the definition of QSBC Share and paragraph (b) of the definition of "small business corporation" in subsection 248(1) of the Act. ...

Our Comments Paragraph 5 of IT-268R3 states, in part, that “... proceeds of disposition otherwise determined' means the amount of consideration paid or payable by a child on a transfer of farm property. ...

Taxation Year Date of Deposit for Deduction to Spousal By Contributor RRSP Amount 1986 February 5, 1987 $1,000 1987 January 1, 1988 $1,000 1988 March 1, 1989 $ 500 The entire amount is withdrawn from the spousal RRSP on January 1, 1991. ...

Barabash of Policy & Systems Branch. We advised him that the information presently available is insufficient for us to express a definitive opinion. ...