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7 February 1991 Income Tax Severed Letter- Advanced tax rulings — repayment of fees Unedited CRA Tags Interpretation Act 31(2) Dear: XXX Mr. ...

7 November 1990 Income Tax Severed Letter- Depreciable property — allocation of proceeds on death Unedited CRA Tags 70(5)(b) QUESTION I-99 DEPRECIABLE PROPERTY- ALLOCATION OF PROCEEDS ON DEATH Assume a taxpayer dies owning several assets of the same class of depreciable property. ...

7 December 1991 Income Tax Severed Letter- Deferred salary leave plans — leave period Unedited CRA Tags Reg. 6801(a)(i) Dear Sir: Re: Deferred Salary Leave Plans- Leave Period This is in response to our telephone conversation (Baldwin/XXX) on December 11, 1991 concerning paragraph 6801(a)(i) of the Income Tax Regulations. ...

7 November 1991 Income Tax Severed Letter- Shareholders' agreement — term preferred shares Unedited CRA Tags 248(1) Question 25- Shareholders' Agreement- Term Preferred Shares Shareholders' agreements may include provisions which require that a shareholder wishing to sell his shares may only do so if the same offer is made by the prospective purchaser to the other shareholders. ...

12 March 1981 Income Tax Severed Letter RRRR38- Foreign accrual property income taxation — deceased individual Unedited CRA Tags 94(1)(b)(i)(B), 94(1)(b)(i)(C) XXX This is in reply to your letter of February 13 concerning clauses 94(1)(b)(i)(B) and (C) of the Income Tax Act. ...

18 July 1980 Income Tax Severed Letter RRRR13- Transfer by non-resident of registered pension plan amounts — Forest et al decision Unedited CRA Tags 204.1, 212(1)(h) This is in response to your memo of July 16 concerning the implications of the recent Federal Court case of Forest et al (1980 DTC 6149). ...

29 April 1980 Income Tax Severed Letter RRRR10- Non-resident individual employed in Canada — rollover of retiring allowance into registered retirement savings plan Unedited CRA Tags 60(j), 2(3), 248(1), 217 A non-resident individual has been employed as president of a Canadian company for several years and recently received a retiring allowance. ...

29 April 1988 Income Tax Severed Letter 5-5527- [] Unedited CRA Tags 212(1)(b)(vii), 212(13.2) XXXX R.H. ...

7 January 1986 Income Tax Severed Letter A-2040- [] Unedited CRA Tags 212(1), Canada–U.S. ...

9 December 1991 Administrative Letter 9133116 F- RRSP Advantage — Mortgage Rate Reduction Unedited CRA Tags 146(2)(c.4), 146(13.1) 7-913311 24(1) RRSP promotion: This is in reply to your memorandum of November 29, 1991 requesting our opinion as to whether there is an advantage when the aforementioned bank reduces the mortgage rates for annuitants with a specified amount in their RRSPs. ...