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CONFERENCE SECTION: 80(1)(b), REG 5400, 245(2)] DRAFT PRAIRIE PROVINCES TAX CONFERENCE MAY 19 & 20, 1992 Question 11 Paragraph 80(1)(b) and Regulation 5400 of the Income Tax Act. ...

Ltée en échange de 10 % des actions émises d'une catégorie donnée de son capital-actions pour permettre à Canco de tirer avantage de la mesure de roulement prévue au paragraphe 85.1(3). ...

Day ' A.M. Smiley DE 957-2136 SUBJECT: Blocked Currency Donations FILE 7-4840 OBJET: DOSSIER We are writing in reply to your memorandum of March 28, 1990, wherein you requested our views regarding the above mentioned subject relative to the questions posed in the March 2, 1990, letter from Our understanding of the situation set out in letter is as follows: Our Comments We will respond to the questions posed in letter in the order in which they appear. 1. ...

7 November 1991 Income Tax Severed Letter- Undeveloped land, interest, and property taxes Unedited CRA Tags 18(2) Undeveloped Land, Interest, and Property Taxes Department's Position #29 Subsection 18(2) of the Income Tax Act (the "Act") limits the deduction of interest and property taxes in respect of the acquisition and holding of land except to the extent that "... gross revenue, if any, from the land for the particular year exceeds the aggregate of all amounts deducted in computing his income from the land for the year... ...

7 July 1990 Income Tax Severed Letter- Prepayment of debt obligation Unedited CRA Tags 212(1)(b)(vii) Dear Sirs: Re: Prepayment of a debt obligation This is in reply to your letter of June 15, 1990 wherein you requested our opinion on the meaning of the phrase "may not under any circumstances be obliged to pay more than 25% of [...] the principal amount of the obligation" found in subparagraph 212(1)(b)(vii) of the Income Tax Act (the "Act"). ...

As outlined in paragraph 8 of Interpretation Bulletin IT-320R, (Special Release dated May 4, 1984) other requirements to be met include • the amount of the mortgage interest rate and other terms must reflect normal commercial practice, and- the mortgage must be administered as if it were on property owned by a stranger. ...

SUBJECT: PRAIRIE TAX CONFERENCE QUESTION RE CHANGING DESIGNATION SECTION: 60(j.2), 220(3.2), REG 600] PRAIRIE TAX CONFERENCE DRAFT/EBAUCHE May 19 & 20, 1992 Question 19 A taxpayer receives pension income of $6,000.00 in 1990 and purchases an R.R.S.P. in February 1991. ...

" For your information we are enclosing photocopies of the memorandum to and from Legal Services, Corporate Rulings Division, Toronto District Office and Coopers & Lybrand. ...

Detailed Tax Calculation) instead of page 4 of the return (page 4 refers you to Tables A & B). ...

We have also enclosed a 1979 Tax Return & Guide. Of particular interest to you would be the comments in paragraph 67B on page 16. ...