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8 November 1989 Ministerial Letter 74488 F- Tax Executive Institute Conference Unedited CRA Tags 7(1)(a), 7(3), 32.1, 248(1) salary deferral arrangement   November 8, 1989 Vancouver District Office Head Office P.E. ... Harding   (613) 957-3499 Attention: J.C. Fitz-Clarke   File No. 7-4488 Subject:  Tax Executive Institute Conference Attached is our suggested reply to the questions submitted to us relating to the taxation of stock purchase plans. for Director Financial Industries Division Rulings Directorate Vancouver District OfficeTax Executive Institute Conference Question: Large public companies have employee share purchase plans as an incentive to keep long-term employees. ...

8 June 1989 Ministerial Letter 32378 F- Deductibility of Interest on Mortgage Unedited CRA Tags 20(1)(c), 245(2), 245(3), 245(4)   June 8, 1989 S. ... Turner   (613) 957-2094 S. Fish   File No. 3-2378 Subject: 19(1) This letter is to inform you of a ruling request which we received (copy attached) related to taxpayers in your district.  ...

20 November 1990 Ministerial Letter 900518 F- Foreign Tax Credit and IT-270R Unedited CRA Tags 126, 20(11), 20(12)   November 20, 1990 HEAD OFFICE Rulings Directorate   G. ... Calderwood (613) 957-2126 International Audits Division   900518 SUBJECT:  Interpretation Bulletin IT-270R This is in reply to your memorandum dated April 23, 1990 whereby you requested our comments concerning the determination of the amount of "tax paid... to the government of a country other than Canada" for purposes of the foreign tax credit under section 126 and the deductions under subsections 20(11) and (12) of the Act having regard to paragraph 14 of IT-270R. ...

11 September 1989 Ministerial Letter 74288 F- Publication of Advance Income Tax Ruling Unedited CRA Tags 55(3)(b)   September 11, 1989 Publications Division Specialty Rulings Roy C. Shultis, Director Directorate   J.E. Harms Attention:  G.J. O'Reilley 957-2108   File No. 74288 Subject: Publication of Advance Income Tax 24(1) (the "Ruling") This is in response to your memorandum of August 29, 1989 in which you requested our comments as to the suitability of the Ruling for publication.  ...

Prima   (613) 957-2060 19(1) May 28, 1990 Dear Sirs: This is in reply to your letter of March 19, 1990.  ... Our Comments 1.     A paragraph 6(1)(a) employment benefit occurs if, for example, the employer itself provides Mr. ... A by the employer, the gross amount is more properly included in section 5 "salary, wages and other remuneration". 2.      ...

2 May 1990 Ministerial Letter 59438 F- Loan by Corporation to Partnership Unedited CRA Tags 15(2) 24(1) File No. 5-9438   M. Eisner   (613) 957-2138 Attention: 19(1) May 2, 1990 Dear Sirs: This is in reply to your hand written memorandum of January 16, 1990 stating your conclusion that where a loan is made by a corporation to a partnership of which the owner of the corporation  is a member, paragraph 15 of Interpretation Bulletin IT-419 confirms that the loan would not be subject to subsection 15(2) of the Income Tax Act. ...

13 August 1990 Ministerial Letter 59718 F- Société en nom collectif Unedited CRA Tags 115(1)(a)(ii), 96(1) 24(1) 5-9718   O. Laurikainen   (613) 957-2129 Attention: 19(1) August 13, 1990 Dear Sirs: Re: Société en Nom Collectif ("SNC") This is in response to your letter of March 9, 1990. ...

(a)     Can a partnership be related to a corporation? (b)     Can partnerships be related? ...

29 March 1990 Ministerial Letter 59598 F- Immigrant's Deductions Unedited CRA Tags n/a 19(1) File No. 5-9598   J.D. Jones   (613) 957-2104 March 29, 1990 Dear Sirs: Re: Immigrant's Deductions This is in reply to your letter of February 6, 1990, wherein you requested our comments concerning deductions available to immigrants in the following situation. ...

19 September 1991 Ministerial Letter 91M09128 F- Allocation of Income and Losses of a Partnerhip Unedited CRA Tags 103(1) QUESTION 24.      ... Answer 24.     It is difficult to give a specific reply to this enquiry because the question of whether a particular allocation would result in the application of subsection 103(1) of the Act would depend on the circumstances of each particular situation. ...