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Snider Specialty Rulings Section Chief Directorate Advanced Audit & Investigation M. ...

You might also wish to refer to the following tax cases that comment on the type of situation to which either paragraph 18(1)(e) or subsection 245(1) could apply: Day & Ross Ltd. v. ...

Yours truly, Section Chief Leasing & Financing Section Financial Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...

Our Views The Department's views regarding this issue are described in Question # 37 of the Revenue Canada Round Table at the 1989 CTF Conference wherein we stated: "It is our view that a corporate partner would normally be carrying on the business carried on by a partnership. ...

Burke (613) 957-8953 Enquiries & Office Examination 7-922366 Registered Retirement Income Fund ("RRIF") Fair Market Value ("FMV") of Property This is in reply to your memorandum of August 6, 1992 which relates to an enquiry you received from the 24(1) Relevant to 24(1)'s enquiry, you ask (a) when it is acceptable, if ever, to write-down the value of the assets in an RRIF, and (b) how you can assure the individual clients that the minimum RRIF payments reflect an accurate FMV at the beginning of the year. ...

" In our view, the phrase "the use or the right to use" would encompass the situation where a Canadian lessee sublets the property to another non-arm's length Canadian person. ...

Prepared by: Tim Kuss Date: November 26, 1992 Control #: 923514 ...

We advise that, as noted in your letter, the explanatory notes accompanying Bill C-139 indicated the deletion of the phrase was "... as a consequence of the general restriction provided in section 67.1 on the deductibility of meal expenses to 805 of their cost" and, accordingly, it is our view that meals and lodgings will continue to be included in the interpretation of "travelling expenses" subject to the other restrictions in the Act on the deductibility of such expenses. ...

Current Amendments & Regulations Division ...

Subject: VESTING-EMPLOYER CONTRIBUTIONS PAID BY EMPLOYEE Section(s): 60(j.1)] Supply and Services Canada CJA 9007-7 & 9006-25-5 Government Operational Services Ottawa, Ontario 5-920538 K1A 0S5 D.S. ...