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4 January 1993 Income Tax Severed Letter 9232447 F- Pension Tax Credit on Surrender of Annuity Contract Unedited CRA Tags 118(7), 12.2, 56(1)(d.1)   January 4, 1993 WINDSOR DISTRICT OFFICE Personal and General Enquiries and Office Examination Section Attention:  D. ...

13 January 1993 Income Tax Severed Letter 9232775 F- Single-purpose Corporation- Personal-use Assets Unedited CRA Tags 15(1)   923277 XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Single-purpose Corporations Holding Personal-use Assets This is in reply to your letter of October 29, 1992 in which you requested our opinion concerning single-purpose corporations holding personal-use assets. ...

Chief Services, Public Utilities & Exempt Corporations Section Corporate Rulings Division Corporate Rulings Directorate Legislation Branch ...

McIntyre Non-Resident Project Team Accounting & Collections Division DSD/hm 96(1.1) Reg. 105 212(5) Article XIIIC- "old" U.S. ...

As pointed out in paragraph 5 of IT-442 "... a bad debt may be claimed in a taxation year only if the debt became bad in that year regardless of brow long the debt may have been outstanding. ...

" This principle was subsequently followed by the Supreme Court of Canada in Savage where the court interpreted the words "... benefits...in respect of, in the course of, or by virtue of an office or employment". ...

& Mrs. X) became resident in Canada. The shareholders of the corporation however do not alter. ...

29 July 1980 Income Tax Severed Letter July 29, 1980 Policy & Systems Non-Corporate Rulings Division M. ...

Section 70(1) of CBICA stipulates that the insurer must provide: "-- a statement of the conditions and affairs of the company on the 31st. day of December in each year, showing the assets and liabilities of the company-- together with such other information as the Minister may from time to time deem necessary. ...

Dictionary definitions also confirm this- see Funk & Wagnells- that which is obtained as an advantage;- a desired acquisition; Shorter Oxford- increase, of possessions, resources, or advantages, consequent on some action or event;- the action of acquiring; Concise Oxford- increase of possessions;- acquisition of wealth. ...