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DM'S OFFICE (2) YS # 96-02118M ASSOCIATE DEPUTY MINISTER (1) ADM'S OFFICE (3) PENDING RETURN TO INCOME TAX RULINGS AND INTERPRETATIONS DIRECTORATE 15TH FLOOR, ALBION TOWER Signed on April 11, 1996 XXXXXXXXXX Dear XXXXXXXXXX: The Honourable Jane Stewart, Minister of National Revenue, has asked me to reply to your letter of March 6, 1996, concerning your deferred salary leave plan. ...

27 July 1993 Ministerial Letter 9321398 F- Fishermen and Unemployment Insurance Unedited CRA Tags 28(1), 56(1)(a)(iv)   ISSUE SHEET FISHERMEN AS EMPLOYEES- UNEMPLOYMENT INSURANCE Issue Individuals engaged in fishing are arranging their affairs so that they may be insured as an employee under the Unemployment Insurance Act where the individual is engaged under a contract of service, rather than as a fisherman under the Unemployment Insurance Fishermen's Regulations. ...

Yours sincerely, September 15,1995 File # 4-952473 ...

Principal Issues: Basic information on SRED tax credit Position: Basic information provided Reasons: For information only March 8, 2000 Assessment & Collections Branch Income Tax Rulings Directorate Ministerial Correspondence P.G. ...

Specifically, your letter refers to a May 21, 1999 article from the Globe & Mail which mentions that a Revenue Canada spokesman stated that a return of capital is tax-free only if a company is being wound down. ...

14 August 1989 Ministerial Letter 89M08178 F- Certified Short Production- Revocation of Certificate Unedited CRA Tags 1104(10)(b), 1104(2)   August 14, 1989 Bryan Dath Tax Avoidance Section Director J.G. ...

One of the requirements for the application of paragraph 125(7)(d) of the Act is that the "... incorporated employee would reasonably be regarded as an officer or employee of the person... to whom or to which the services were provided but for the existence of the corporation... ...

13 June 1990 Ministerial Letter 90116008 F- Use of Prescribed Interest Rates Unedited CRA Tags n/a Minister (2)/DM's Office Y.S. 90116008 Central Records Author/Section Chief District Office Research File Taxpayer's File Return to Specialty Rulings, Room 303 Met.   ...

27 April 1992 Ministerial Letter 9206948 F- Retiring Allowance Unedited CRA Tags 60(j.1) MINISTER/DM'S OFFICE                YS:  92-1736T SECTION CHIEF DISTRICT OFFICE, OR CORPORATE CASE FILE RETURN TO RULINGS, ROOM 303, METCALFE BLDG April 21, 1992 19(1) The Honourable Otto Jelinek, Minister of National Revenue, has asked me to reply to your letter of February 11, 1992, concerning the amount of your retiring allowance that can be transferred to a Registered Retirement Savings Plan (an RRSP). ...

Principal Issues: whether an extended cab truck with rear folding, or folding jump seats behind the driver's bench seat is an automobile for the purpose of the standby charge Position: depends on the percentage of use of the vehicle for transporting goods, equipment or passengers in the course of earning income Reasons: a club cab, crew cab or extended cab truck has seating capacity for more than driver + 2. ...