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20 February 1992 Income Tax Severed Letter 9202997- Registered retirement savings plan trust — death of annuitant Unedited CRA Tags 146(4), 146(1), 146(8.8), 104(13), 104(6) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Duff Chief Rulings Directorate T3 Programs Section 957-8953 T2 & T3 Programs Division Attention: Aileen Wade 7- 920299 RRSP Trusts: Tax Reporting after Death of Annuitant This is in response to your memorandum of January 29, 1992 requesting that we review your proposed reply to XXX After reviewing the aforementioned draft we do not see any inaccuracies in it. ...

5 May 1992 Income Tax Severed Letter- Registered retirement savings plans — promotional activities by bank Unedited CRA Tags 146(2)(c.4) This is in reply to your memorandum of April 15, 1992, in which you ask us to review the letter of February 21, 1992, from the above-noted Bank concerning their promotional activities XXX. ... We therefore confirm our interpretations as contained in our previous correspondence noted above. for Director Financial Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch [SUBJECT: CAPITAL GAINS EXEMPTION & GAAR SECTION: 110.6(1), ...

7 May 1991 Income Tax Severed Letter- Ontario Current Cost Adjustment and the Ontario R & D Superallowance Unedited CRA Tags 12(1)(x), 13(7.1), 37(1)(d), 127(11.1) Dear Sirs: Re: Ontario Current Cost Adjustment and the Ontario R & D Super Allowance This is in reply to your letter of March 13, 1991 concerning the Ontario Current Cost Adjustment and the Ontario Research and Development Superallowance. ...

9 December 1991 Internal T.I. 9122907 F- DSLP for Teachers — Calculation of Six Months Unedited CRA Tags 6801(a) 7-912290 24(1) Re:  Deferred Salary Leave Plan We are writing in reply to your letter of June 7, 1991, to the Kitchener District Taxation Office which was forwarded to us on August 1, 1991.  ... Source Deductions  —  Rulings Kitchener District Office ...

3 May 1989 Income Tax Severed Letter 7-3790- [Self-Administered RRSP – Mortgage Investment] REVENU CANADA TAXATION MEMORANDUM DATE May 3, 1989 TO- VICTORIA DISTRICT OFFICE Public Affairs Division (1228 106 0 0) FROM HEAD OFFICE Financial Industries Division M. ... Chief Deferred Income Plans & Trusts Section Financial Industries Division Rulings Directorate ...

29 July 1988 Income Tax Severed Letter 5-6297- [] B. Fioravanti (613)957-8962 XXXX July 29, 1988 Dear Sirs: This is in reply to your letter of July 5, requesting our interpretation of the expression "an annuity commencing at maturity" as used in paragraph 146(1)(i.1) of the Income Tax Act (the "Act"). "Maturity" is defined in paragraph 146(1)(d) of the Income Tax Act to mean "... the date fixed under a retirement savings plan for the commencement of any retirement income... ...

1 March 1988 Income Tax Severed Letter 5-5155- [Sections 25 & 99 of the Income Tax Act] E. Gillman 613)957-8953 March 1, 1988 Dear Sirs, Re: Sections 25 & 99 of the Income Tax Act (the "Act") This is in reply to your letter of November 18, 1987 and following our telephone conversation (Gillman/XXXX) of February 16, 1987 concerning the election of a year-end by an individual who is a member of a partnership after having the partnership elect to rollover all of its assets to a taxable Canadian corporation in virtue of subsection 85(2) of the Act. ...

27 June 1986 Income Tax Severed Letter 5-1749- [] XXXX K.B. Harding (613) 957-2129 June 27, 1986 Dear Sirs: This is in reply to your letter of January 7, 1985 wherein you questioned the meaning of the words "profits" for purposes of paragraph 2 of Article XVI of the Canada-U.S. ... Paragraph 2 of Article III of the Convention states "... any term not defined therein shall, unless the context otherwise requires and subject to the provisions of Article XXVI (Mutual Agreement Procedure), have the meaning which it has under the law of the State concerning the taxes to which the Convention applies". ...

4 May 1989 Income Tax Severed Letter 7-3745- [] May 4, 1989 HALIFAX DISTRICT OFFICE Attention: J.R. ... Chief Leasing & Financing Section Financial Industries Division Rulings Directorate ...

The relevant exclusions are: Paragraph (l) – if the non-resident trust is a foreign affiliate of the taxpayer for purposes of section 233.4 of the Act. ... Paragraph (m) – if the interest in the non-resident trust was not acquired for consideration by the taxpayer, or certain other persons. ... Paragraph (n) – if the trust is described in paragraph (a) or (b) of the definition of “exempt trust” in subsection 233.2(1) of the Act. ...