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Such internal costs could include (a)       full salaries and benefits of employees who work on the plan full time, (b)       the pro-rata share of salaries and benefits of employees who work on the plan part-time, (c)       the full cost of any equipment and supplies purchased or leased solely to help maintain and operate the plan, (d)       the pro-rata cost of any equipment and supplies purchased or leased in part to help maintain and operate the plan, and (e)       that portion of the rent and overhead that is attributable to the employees and equipment operating and maintaining the plan. ... Where the relevant costs are reasonable, our views on the five points raised on page 2 of your letter are as follows: 1.      ... The method (e.g., implicit or explicit) by which the actuary reflects the fact that such costs were considered is immaterial in and of itself. 3.      ...

14 December 1989 Ministerial Correspondence 32464B- Demande de décisions anticipées- Avis de fermeture du dossier Unedited CRA Tags n/a 19(1) 3-2464   Benoit Mandeville   (613) 957-8982 Le 14 décembre 1989 Messieurs, Objet: 19(1) & 24(1) Demande de decisions anticipées La présente fait suite à notre lettre du 16 novembre 1989 dans laquelle nous vous avons demandé de nous faire parvenir certains renseignements supplémentaires, indispensables afin de donner suite au traitement de votre demande de décisions anticipées, à l'intérieur d'un délai de quinze (15) jours à défaut de quoi nous allions présumer de votre intention de ne pas donner suite à votre demande. ...

6 October 1989 Ministerial Correspondence 89M10424 F- Proposed Conference Attendance 1990-1991 Unedited CRA Tags n/a   October 6, 1989 Carol Waite Technical Interpretations 10th Floor, MacDonald Building Division   A.G. Cockell   957-9226 SUBJECT: PROPOSED CONFERENCE ATTENDANCE 1990-1991 Consideration could be given to sending one person from this Division (Director or Chief) to the Canadian Tax Foundation Annual Conference. ...

Under this subsection, an amount paid is deductible by the payer in the year paid (and is included in the income of the payer's spouse or former spouse under paragraph 56(1)(b) of the Act) if all of the following requirements are met: 60(b), 56(1)(b) a)     the amount is paid as alimony or other allowance for the maintenance of the spouse (or former spouse), children of the marriage, or both; b)     the spouses (or former spouses) are living apart at the time the payment is made and throughout the remainder of the year pursuant to a divorce, judicial separation, or written separation agreement; c)      the amount is paid pursuant to a decree, order or judgement of a competent tribunal or pursuant to a written agreement; d)        the payment is one of a series payable on a periodic basis; and e)        the amount is paid or deemed to be paid to the spouse or former spouse. ...

6 November 1989 Ministerial Correspondence 89M11554 F- Pension Reform Reviewers Unedited CRA Tags n/a   November 6, 1989 PENSION REFORM REVIEWERS CURRENT AMENDMENTS   AND REGULATIONS   DIVISION Enclosed for your review is a copy of the November 2., 1989 version of the PA and RPP regulations. ...      - A.B. Adler, Financial Industries Division- P. Cloutier, Registered Pension and Deferred Income Plans Division- C. ...

4 July 1990 Ministerial Correspondence 900954 F- Charity not Qualifying as Non-profit Organization Unedited CRA Tags 149(1), 149(5) 19(1) 900954   Bill Guglich   (613) 957-2102   EACC9488 July 4, 1990 Dear 19(1) This is a reply to your letter of May 28, 1990 concerning your  24(1)  In addition to our comments that follow please refer to our previous letter dated May 24, 1990.  ... An entity that is, in the opinion of the Minister of  National Revenue, a charity (whether registered or  not) can not qualify under paragraph 149(1)(l) of the Act. 134.      ... However we are not in a position to comment on your general statement that this is not uncommon.  136.      ...

25 April 1991 Ministerial Correspondence 910354 F- Retiring Allowance Unedited CRA Tags 56(1)(a)(ii), 248(1) retiring allowance Dear Sirs: Re:  Retiring Allowance This is in reply to your letter dated January 29, 1991 in which you requested our technical interpretation regarding the definition of "retiring allowance" in subsection 248(1) and the application of subparagraph 56(1)(a)(ii) and section 6 of the Income Tax Act (the "Act") to the following situation ISSUE More specifically you have asked: (1)       whether the equivalent of three months salary at the date of termination of employment representing pay in lieu of notice and the equivalent of one half month's salary or wages at the date of termination of employment for each full year of service, pro-rated and diminished by any amounts received in respect of severance and/or termination payments under any applicable statutes, would qualify as a retiring allowance as the term is defined in subsection 248(1) of the Act; (2)       whether our response to (1) would change if the employee chooses periodic payments rather than a lump sum payment; (3)       whether our response to (1) would change if the employment termination were voluntary, and; (4)       whether our response to (1) would change if the amounts were paid pursuant to either the employment contracts or under relevant employment standards legislation. ...

10 October 1989 Ministerial Correspondence 89M10024 F- Computer Room Tours Unedited CRA Tags n/a   October 10, 1989 Mr. ... (Ross) Couchman Provincial and International Acting Manager Relations Division Computer Operations Legislative & Computer Services Division Intergovernmental Room 1060-TC Affairs Branch 875 Heron Road David R. Senécal      957-2074 COMPUTER ROOM TOURS We thank you for your memorandum of September 25, 1989, and we apologize for the lack of advance notice. ...

27 September 1989 Ministerial Correspondence 89M09364 F- Remission of Tax Paid on CSB Interest Inadvertently Reported Twice Unedited CRA Tags n/a   September 27, 1989 A.G. Cockell, Chairman  Technical Interpretations Remission Committee Division   D.M. Lanos   957-9231 Subject: 19(1) The taxpayer requests a remission of the 1984 income tax that was paid by her on Canada Savings Bonds interest inadvertently reported twice. 24(1) The taxpayer's case was referred to this Division on September 15, 1989, by P. ...

.- Adverse Decision Unedited CRA Tags n/a   November 14, 1989 Ms L.C. Tremblay Technical Interpretations A/Director Division Appeals & Referrals Division S. Parnanzone   957-9232 ATTN:  M.S. Lalonde Subject: HENRY R. HEWITT V. ...