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8 June 1989 Administrative Letter 73886 F- Taxability of a Retainer as Employment Income Unedited CRA Tags 9   June 8, 1989 Enquiries and Taxpayers Small Business and Assistance Division General Division P. ...

23 April 1990 Administrative Letter 74796 F- Meaning of "Paid" Unedited CRA Tags 2900(2)(b), 78   April 23, 1990 Scientific Research Audit Specialty Rulings Directorate Applications Section J.D. ...

You question our statement that reads, ".... where the producer association is a taxable entity, tax could be exigible on the portion of the interest paid by the federal government". ...

Source Deductions  —  Belleville District Office ...

With respect to your comments concerning the formula for allocating the capital gains exemption suggested in our letter to     XXXXXXXXXX we recognize the possibility that in certain instances we may not be able to release information which the purchaser needs in order to calculate the least amount as established by the formula. ...

25 August 1993 Administrative Letter 9311696 F- Flow Through Shares Unedited CRA Tags ITR 6202.1   Specialized Audit Programs SectionResource Industries Mara D. ...

30 September 1993 Administrative Letter 9322086 F- Transport Employee Expense Unedited CRA Tags 8(1)(g) Head Office- Appeals Branch Business and General Appeals & Referrals Division Division Attention:  Neil Wilson XXXXXXXXXX Transport Employee Expense- Paragraph 8(1)(g) This is in reply to your memorandum of August 4, 1993 in which you requested our views on the deductibility of meal expenses under paragraph 8(1)(g) of the Income Tax Act (the Act) in respect of an individual who is employed by placement agencies and assigned to trucking firms. ...

2 December 1991 Administrative Letter 9130676 F- Resident or Non-resident of Canada Unedited CRA Tags 250(1)(e), 2(3), 115(1)(a)   913067 19(1) This is in reply to your memorandum of November 4, 1991 wherein you requested our opinion concerning the withholding of tax, CPP and UIC contributions with respect to salary paid to the above-referenced taxpayer. 24(1) Paragraph 250(1)(e) of the Income Tax Act (the "Act") clearly indicates that a spouse of an officer or servant who was living with the officer or servant is deemed to be a resident of Canada if the spouse was resident in Canada in any previous year. ...

The Annual Adjustment will be determined by the following formula: Value = ((A/2)/B) where A = The average for the last three fiscal years of the amounts determined for each fiscal year by taking XXXXXXXXXX percent (XXXXXXXXXX%) of the sales revenue for a year plus XXXXXXXXXX percent (XXXXXXXXXX%) of the Mean Market Price Earnings Multiple multiplied by the consolidated net income after taxes as reported in the consolidated financial statements of the Company for that year. B = The sum of the issued and outstanding Class XXXXXXXXXX common shares and Class XXXXXXXXXX common shares of the Company (after the stock split described in paragraph 5 above) and the Authorized Units as of the last day of the particular fiscal year. ...

Position TAKEN: A GIFT IN KIND COULD QUALIFY AS GIFT FOR PURPOSES OF SECTIONS 110.1 & 118.1. ...