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12 January 1990 Administrative Letter 59106 F- Non-resident Withholding Tax Unedited CRA Tags Part XIII 19(1) File No. 5-9106   A. Seidel   (613) 957-8960 January 12, 1990 Dear Sir: This is in reply to your letter of November 17, 1989 and further to our conversation of December 8, 1989 with respect to the withholding of tax pursuant to Part XIII of the Income Tax Act (the "Act") where a non-resident corporation in one country uses a Canadian bank as its agent to make interest or dividend payments to a non-resident in another country. ...

7 June 1990 Administrative Letter 59396 F- Taxable Capital Employed in Canada of Financial Institution Unedited CRA Tags 181.3(1)(a) 24(1) File No. 5-9396   J.P. Dunn   (613) 957-8961 19(1) June 7, 1990 Dear Sir: We are writing in response to your correspondence of January 11, 1990 requesting our interpretation of the phrase "an asset of the financial institution that is tangible property used in Canada" as that term is utilized in draft paragraph 181.3(1)(a) of the Income Tax Act dealing with the proposed Tax on Large Corporations. ...

14 July 1989 Administrative Letter 57786 F- Deductibility of Union Dues Unedited CRA Tags 8(1)(i)(iv), 8(5), 56 19(1) File No. 5-7786   S. Short   (613) 957-2134 July 14, 1989 Dear Sirs: Re:  Deductibility of Union Dues This is in reply to your correspondence dated March 30, 1989, wherein you have queried the deductibility of union dues paid by 24(1) retirees for income tax purposes. ...

3 December 1990 Administrative Letter 903016 F- Private Corporation Status under Canada-Germany Income Tax Convention Unedited CRA Tags n/a 19(1) 903016   M.P. Sarazin   (613) 957-2125 December 3, 1990 Dear Sir: Re:  Article 13 of the Canada-Germany Income Tax Agreement (1981) (the Agreement) We are writing in reply to your letter dated October 18, 1990 wherein you brought to our attention the fact that the assumption made in our letter dated August 14, 1990 that the West-German "Gesellschaft des buergerlichen Rechts" ("GbR") is a private corporation is not correct. ...

25 August 1989 Administrative Letter 58486 F- Regulations to the Income Tax Act Unedited CRA Tags 1100(21)(a)(ii) 19(1) File No. 5-8486   Blair P. Dwyer   (613) 957-2744 August 25, 1989 19(1) Re:  Subparagraph 1100(21)(a)(ii) of the Regulations to the Income Tax Act (Canada) This is in reply to your letter (the "Request Letter") dated August 7, 1989, in which you asked for confirmation of an opinion expressed by an officer of this Department during a telephone conversation on August 6, 1989.  ...

18 December 1989 Administrative Letter 58836 F- Deductibility of Personal Financial Planning Services Unedited CRA Tags 20(1)(bb), 9(1) 19(1) 5-8836   M. Eisner   (613) 957-2138 December 18, 1989 Dear Sirs: This is in reply to your letter of October 4, 1989 concerning the deductibility if the cost of personal financial planning services. ...

Our understanding of the facts in this case is as follows: XXXXXXXXXX the employer has agreed to reimburse an employee's additional child care costs in certain situations. 1.      ... XXXXXXXXXX 2.     An employee attends a course approved by the employer outside the employee's normal work day such that the employee incurs additional child care expenses. ...

Warren   Section Acting Director John Chan   (613) 957-8973 Attn:  Bharat Patel Industry Specialist Services Calgary D.O.                7-913345 Successor Rules- Subsections 66.7(12) and (12.1) This is in reply to your memorandum dated December 3, 1991 and the analysis attached thereto of a hypothetical situation involving the successor rules, namely, subsections 66.7(12) and (12.1) contained in Bill C-18 which received Royal Assent on December 17, 1991. ...

Your correspondence requests a statement addressing the deductibility of moving expenses incurred by instructors on a paid leave of absence to pursue studies at a university located in a city other than   24(1) 24(1)     You have asked that we indicate that a moving expense deduction is available to an individual when the following conditions are met: 1.     the move is necessary to obtain new expertise (and is why the leave is granted by the employer) and 2.      ...

2 March 1990 Administrative Letter 32886 F- Change of Investment from Interest-Bearing to Interest-Free Unedited CRA Tags 12(3), 12(4), 12(9), 54 disposition, ITR 7000(1)(a) 19(1) File No. 3-2886   Peter Lee   (613) 957-2745 March 2, 1990 Dear Sirs: Re:  Advance Income Tax Ruling Request  24(1) We are writing in reply to your letter of December 11, 1989, wherein you requested an advance income tax ruling with respect to  24(1) We are unable to provide the requested advance income tax ruling because your submission did not include all of the material referred to in paragraphs 3, 6, 14, 15 and 16 of Information Circular 70-6R, which set out the specific submissions for an advance income tax ruling application. ...