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20 January 1992 Administrative Letter 9200046 F- 92 Manitoba Rt #19- Forgiveness Of Parnership Loans Unedited CRA Tags 80, 245(2), 246(1), ITR 5400 Q.19          Section 80- Application to Partnerships It appears that the Department considers a partnership to be a taxpayer for the purposes of section 80 given the Department's comments in paragraph 17 of Interpretation Bulletin IT-138R and its responses to Questions 14 and 9 raised, respectively, at the 1988 Canadian Tax Foundation Conference and the 1989 Corporate Management Tax Conference round table sessions.  ...

3 March 1992 Administrative Letter 9204186 F- Pension Splitting Marriage Breakdown Source Deductions Unedited CRA Tags 56(1)(a)(i), 153(1), 60(c)   920418     R.B. Day   (613) 957-2136 March 3, 1992 Source Deductions DivisionA. BissonnetteDirector     19(1)Pension Splitting on Marriage Breakdown Application of 56(1)(a)(i) and 153(1) We are forwarding, for your consideration and reply, the February 6, 1992, Round-Trip memorandum from Source Deductions Division in the Scarborough District Office and the accompanying letter from the taxpayer's representative dated January 14, 1992. ...

29 March 1993 Administrative Letter 9300586 F- Pension Contribution by Employer on Employee's Behalf Unedited CRA Tags 147.2(4) March 29, 1993 Registered Plans Division      Financial Industries S. ... Kotlar      Division Director      D.S. Delorey  957-8953 Attention:  Mike Bennett XXXXXXXXXX This is in reply to your memorandum of December 31, 1992. ...

16 January 1990 Administrative Letter 74436 F- Debtor's Gain on Settlement of Debts Unedited CRA Tags 80(1)   January 16, 1990 Hamilton District Office Specialty Rulings Chief of Audit  Directorate   P. ... (our emphasis)      whereas the reference found in the commercial publication which you consulted stated in part that:      (6)  "For the purposes of subsection (3) and of subsection 24(3), a document evidencing indebtedness to a person to whom shares are to be issued...does not constitute property." (our emphasis)      It is clear that by exchanging the incorrect word, "to" for the correct word, "of", the provision acquires an entirely different meaning.      24(1)      For purposes of subsection 80(1), the "amount paid" would be the fair market value of the shares issued, the "principal amount" would be expressed in CDN $ at the prevailing exchange rate and the "amount for which the obligation was issued" would be expressed in CDN $ at the historical exchange rate.  ...

18 July 1989 Administrative Letter 58306 F- Minimum Amount under RRIF- Fair Market Value of Property at Beginning of the Year Unedited CRA Tags 146.3(1) minimum amount 19(1) File No. 5-8306   W.C. Harding   (613) 957-3499 July 18, 1989 This is in reply to your letter of June 26, 1989 wherein you requested our interpretation of the term "Fair Market Value" as it is used in paragraph 146.3(1)(b.1) of the Income Tax Act (the "Act") and whether or not it includes accrued interest on debt obligations and "ex-dividends". "Fair market value" is not defined in the Act but has been defined by the courts as being:      "... the highest price available in an open and unrestricted market between informed, prudent parties, acting at arm's length and under no compulsion to act, expressed in terms of money or money's worth". ...

7 April 1992 Administrative Letter 9209186 F- Repayment Of Return Of Pension Contributions Unedited CRA Tags 147.2(4)(c)     5-920918   P. Spice   957-8953 April 7, 1992 Client Assistance DirectorateFinancial Industries Division Mrs. ...

3 June 1992 Administrative Letter 9216226 F- Film Partnership Unedited CRA Tags 9, 96(2.2)(d)(ii)     921622   Marc Vanasse   (613) 957-8953 June 3, 1992 Vancouver District OfficeManufacturing IndustriesTax Avoidance DivisionPartnerships & Trusts Division R. ... Amlani Section 145-12      24(1) Matching Principle of Income and Expenses This is in reply to your facsimile dated May 27, 1992 wherein you requested that we confirm the Department's existing policy regarding certain financing arrangements, such as the one mentioned above, in which a limited partnership enters into an arrangement with another taxpayer whereby the limited partnership agrees to pay certain of the other taxpayer's expenses and claims a deduction for them in the year of the payment. ...

Bernhard BuetowChiefTechnical Review SectionPublications DivisionLegislative and Intergovernmental Affairs Branch   Appendix   G. Donell   957-9231 1.     SOS.1 "Medical Expenses"      As per discussions with Corinne Salvason, we have attached copies of correspondence between Specialty Rulings and the Thunder Bay district office dated October 8, 1986 in support of the response.       ... In consideration of the above comments we advise striking paragraph 3 of The SOS.3 response.       ...

1993 Administrative Letter 9337176 F- Deferred Salary Leave Plan Unedited CRA Tags ITR 6801(a) RULINGS DIRECTORATE CORRESPONDENCE SUMMARY PRINCIPAL ISSUES: Whether dslp meets requirements of ITR 6801(a) POSITION TAKEN: Yes, except 6801(a)(iii) REASONS FOR POSITION TAKEN: Routine LEGAL: FINANCE OPINION: JURISPRUDENCE: RCT PUBLICATIONS: HAA NUMBER: 7680-4-2 February 1, 1994 Head Office      Head Office Source Deductions Division      Rulings DirectorateA. Bissonnette, Director      (613) 957-8953 Attention:  R. Cousineau DO & TC Support Services Deferred Salary Leave Plan This is in reply to your memorandum of December 21, 1993, in which you ask us to review and comment on a deferred salary leave plan (the "Plan") submitted to the XXXXXXXXXX Our comments follow. ...

Paul's 1989 world income consisted of the following amounts all expressed in Canadian currency: 1)     $18,000 salary earned in Canada; 2)     $15,000 salary earned in France; and 3)     $1,000 United States source interest.      Since Paul spent more than 183 days in Canada he will be deemed to be a resident of Canada and will be subject to tax in Canada on his world income ($18,000 + $15,000 + $1,000 = $34,000).  ... You have indicated that non-residents may not claim any non-refundable tax credits unless they meet this test.       ...