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20 February 1990 Ministerial Correspondence 59414 F- Deduction in Computing Income of Trust Unedited CRA Tags 104(4)(a), 104(6)(b), 104(5), 104(5.2), 104(13.1), 104(13.2), 111(1.1), 111(3), 111(1)(a), 110.6 19(1) File No. 5-9414   D.S. Delorey   (613) 957-3495 February 20, 1990 Dear Sirs: This is in reply to your letter of January 15, 1990 concerning the computation of income and losses of a trust described in paragraph 104(4)(a) of the Income Tax Act (the "Act"). ...

20 August 1990 Ministerial Correspondence 900404 F- Scientific Research and Experimental Development Unedited CRA Tags 37(1) 24(1) 900404   C.R. Bowen   (613) 957-2096 Attention: 19(1) EACC9294 August 20, 1990 Dear Sirs: Re: Scientific Research and Experimental Development ("SR&ED") We are writing in reply to your letter of April 10, 1990 and further to our telephone conversation of July 16, wherein you requested our comments on the phrase "entitled to exploit the results of such SR&ED" in subsection 37(1) of the Income Tax Act (the "Act").  ...

18 October 1989 Ministerial Correspondence 74304 F- Principal Residence Rules Unedited CRA Tags 2(3), 54 principal residence, 40(2)(b), 69(1)(b)(ii), 110.6(3), 115(1), 248(1) taxable Canadian property, 250(1)(a)   October 18, 1989 Non-Resident Taxation Business and General Division Division Mr. ... Jones A/Director 957-2104   File No. 7-4304 Subject: Principal Residence Rules This is in reply to your memorandum of September 1, 1989 wherein you requested our opinion on the applicability of the principal residence rules pursuant to paragraphs 54(g) and 40(2)(b) of the Income Tax Act (the "Act") in the following situation. 24(1) You have requested our opinion on whether the individual, in this case, is entitled to claim the principal residence exemption pursuant to paragraph 40(2)(b) of the Act or, if not, whether the taxpayer is entitled to claim a capital gains deduction pursuant to subsection 110.6(3) of the Act. ...

15 November 1989 Ministerial Correspondence 74064 F- Income in Year of Immigration Unedited CRA Tags 115(2)(e)(i), 122.2(1)(b)(i), 114, 3, 2(2), 249(1)(b)   November 15, 1989 Non-Resident Foreign Section Taxation Division Specialty Rulings Assessing Program Section Directorate Room 300C G. Kauppinen 360 Laurier Street West 957-2123 Attention:  Paul Coleman   File No. 7-4064 Subject: Child Tax Credit and Subparagraph 115(2)(e)(i) Income This is in reply to your memorandum dated June 26, 1989 wherein you have requested our opinion as to whether income of a taxpayer which was excluded from the computation of taxable income pursuant to subparagraph 115(2)(e)(i) is included in the computation of income pursuant to subparagraph 112.2(1)(b)(i) in the year the taxpayer immigrates to Canada. ...

23 February 1990 Ministerial Correspondence 59374 F- Income Attribution Rules Unedited CRA Tags 74.1, 103(1.1), 74.5(1), 97(2) 19(1) File No. 5-9374   A.W. Larochelle   (613) 957-2140 February 23, 1990 Dear Sirs: Re:  The Income Attribution Rules Subsections 74.1 and 103(1.1) of the Income Tax Act (the "Act") This is in reply to your letter concerning the attribution rules in section 74.1 of the Act. ...

18 October 1989 Ministerial Correspondence 58444 F- Wittholding of Tax- Wrongful Dismissal Payment Unedited CRA Tags 56(1), 60, 153(1)(c), 248(1) retiring allowance 19(1) File No. 5-8444   J.D. Jones   (613) 957-2104 October 18, 1989 Dear Sirs: Re:  Paragraph 153(1)(c) of the Income Tax Act (the "Act") This is in reply to your letter of July 26, 1989, wherein you requested our confirmation of your understanding of the requirements relating to the withholding of tax pursuant to paragraph 153(1)(c) of the Act in the following situation. ...

11 July 1989 Ministerial Correspondence 58104 F- Income Tax Treatment of Payments to Employees on Leave Unedited CRA Tags 60(j.1), 248(1) retiring allowance 19(1) File No. 5-8104   A. Adler   (613) 957-8962 July 11, 1989 Dear Sirs: This is in reply to your letter dated May 15, 1989 concerning the income tax treatment of certain payments to employees who go on "pre-retirement leave". ...

29 January 1990 Ministerial Correspondence 56704 F- Interest Rate Cap Unedited CRA Tags 9, 12(1)(a)(i), 20(1)(m)(ii), 18(9)(a)(i), 18(9)(b) 19(1) File No. 5-6704   M.M. Trotier   (613) 957-8953 January 29, 1990 Dear Sirs: Interest Rate Cap This is in reply to your letter of October 11, 1988 wherein you requested our comments as to the income tax implications to a bank with respect to its participation as vendor or purchaser of an interest rate protection agreement.  ...

20 July 1989 Ministerial Correspondence 58034 F- Mortgage Investment Corporation Unedited CRA Tags 130.1(6) 19(1) File No. 5-8034   A. Seidel   (613) 957-8960 July 20, 1989 Dear Sir: This is in reply to your letter of May 3, 1989, requesting information with respect to Mortgage Investment Corporations ("MIC") as defined in subsection 130.1(6) of the Income Tax Act (the "Act"). ...

12 February 1990 Ministerial Correspondence 59474 F- Capital Gains Exemption and Insufficient Dividend Test Unedited CRA Tags 55(2), 55(3)(a), 84(3), 85(1), 110.6(8), 125(7) Canadian-controlled private corporation, 248(1) cost amount, 248(10), 251(2), 251(6), ITR 6205(1)(a), 6205(2) 19(1) File No. 5-9474   S. Shinerock   (613) 957-2108 February 12, 1990 Dear Sirs: Re:  Subsection 110.6(8) of the Income Tax Act (the "Act") We refer to your letter of December 6, 1989, wherein you requested our views on the application of subsection 110.6(8) of the Act and subsection 6205(2) of the Income Tax Regulations ("ITR") to the following hypothetical situation. ...