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4 September 1990 Administrative Letter 901482 F- Escrowed and Restricted Shares as Investments for RRSPs Unedited CRA Tags 204 qualified investment 24(1) 901482/901576   D. Duff   (613) 957-3498 19(1) EACC9701 September 4, 1990 Dear Madam: This is in response to your letters of June 29 and July 12, 1990 regarding the qualification of escrowed and restricted shares as investments for registered retirement savings plans ("RRSPs"). ...

28 May 1990 Administrative Letter 59646 F- Employee Stock Options Unedited CRA Tags 7 24(1) File No. 5-9646   J.D. Jones   (613) 957-2104 19(1) May 28, 1990 Dear Sirs: Re:  Section 7 of the Income Tax Act (the "Act") This is in reply to your letter of February 21, 1990, wherein you requested a technical interpretation with respect to the application of subsection 7(1.1) of the Act in the following situation. ...

7 September 1989 Administrative Letter 57776 F- Insurance Proceeds Unedited CRA Tags 12(1)(f), 13(21) proceeds of disposition, 56(2) 19(1) File No. 5-7776   J.D. Brooks   (613) 957-2097 September 7, 1989 Dear Sirs: Re:  Paragraphs 12(1)(f) and 13(21)(d) of the Income Tax Act (the "Act") This is in reply to your letter of March 31, 1989 in which you requested our opinion with respect to a situation you described as follows: 24(1) It is apparent that the situation you described relates to specific taxpayers.  ...

27 March 1990 Administrative Letter 59726 F- Deferred Salary Leave Plan- Withholding of CPP, UIC and Income Tax Unedited CRA Tags n/a 19(1) File No. 5-9726   Maureen Shea-DesRosierss   (613) 957-8953 March 27, 1990 Dear Sirs: Re: Deferred Salary Leave Plan ("DSLP") Withholding of Canada Pension Plan ("CPP") Unemployment Insurance ("UI") and income tax This is in reply to your letter of March 2, 1990 wherein you request information concerning the above-mentioned subject. ...

4 July 1989 Administrative Letter 58156 F- Employee Benefit Plan Unedited CRA Tags 153(1)(a), Part 1, 115(1)(a) 19(1) File No. 5-8156   W.C. Harding   (613) 957-3499 July 4, 1989 Dear Sir: Re: Employee Benefit Plan ("EBP") This is in reply to your letter of May 25, 1989 wherein you requested our comments on the taxation of payments out of an EBP to a resident of the United States. ...

23 August 1990 Administrative Letter 901466 F- Employees Profit Sharing Plan- Employee Leaving in Middle of the Year Unedited CRA Tags 144, 2(3), 6(1)(d), 115 24(1) 901466   Maureen Shea-DesRosierss   (613) 957-8953 Attention: 19(1) EACC9276 August 23, 1990 Dear Sirs: Re: Employees Profit Sharing Plan ("EPSP") Section 144 of the Income Tax Act (the "Act") This is in reply to your letter of June 21, 1990 concerning the above-mentioned subject. ...

18 June 1990 Administrative Letter 59786 F- Stock Options Granted to Non-residents Unedited CRA Tags 7 24(1) File No. 5-9786   J.D. Jones   (613) 957-2104 Attention: 19(1) June 18, 1990 Dear Sirs: Re:  Stock Options Granted to Non-Residents This is in reply to your letter of March 19, 1990, wherein you requested our opinion on the applicability of section 7 of the Income Tax Act in the following situation. ...

14 November 1989 Administrative Letter 58506 F- Meaning of Replacement Property Unedited CRA Tags 44(5) 19(1) File No. 5-8506   M. Eisner   (613) 957-2138 November 14, 1989 Dear Sirs: This is in reply to your letter of August 4, 1989 concerning the meaning of "replacement property" in subsection 44(5) of the Income Tax Act. ...

19 April 1990 Administrative Letter 59756 F- Registered Pension Plan Unedited CRA Tags 8(1)(m), 111(1)(a), 111(8) non-capital loss 19(1) File No. 5-9756   A.B. Adler   (613)957-8962 April 19, 1990 Dear Sirs: This is in reply to your letter dated March 13, 1990 in which you requested our views whether certain payments from an insurance company to a registered pension plan ("RPP") would constitute contributions thereto for purposes of paragraph 8(1)(m) of the Income Tax Act ("Act") in the following situation. 24(1) It is not our practice generally to provide written opinions concerning actual and/or completed transactions, however, we are prepared to provide you with the following comments. ...

19 September 1989 Administrative Letter 58466 F- Deductibility of Interest Unedited CRA Tags 97(2) 19(1) File No. 5-8466   Blair P. Dwyer   (613) 957-2744 September 19, 1989 Dear Sirs: Re:  Deductibility of Interest on Money Borrowed by Partnership to return Capital to its Partners This is in reply to your letter dated July 26, 1989 asking for our comments on the above-noted subject in light of the Notice of Ways and Means Motion on interest deductibility (released September 29, 1988). ...