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29 May 1990 Income Tax Severed Letter RRRR384 F- Choix concernant les dividendes en capital — Formule T2054 Unedited CRA Tags 80(1), 83(2) DATE May 29, 1990 TO FROM A Direction des cotisations DE Section des services et des demandes de bilingues renseignements Marc Séguin 957-8973 D.I. ...

In this regard, Di Castri states the following: Prima facie, and in the absence of a stipulation to the contrary, a purchaser who accepts a conveyance of an estate subject to a mortgage is bound under an obligation of conscience to indemnify his vendor-grantor against the mortgage debt; the amount of such debt is in effect part of the purchase money. ...

Di Libero O.S. Laurikainen   (613) 957-2125   File No. 7-4205 SUBJECT:  Article XIII (9) of the Canada-U.S.  ...

The situation upon which we are not prepared to comment at this time is that in which the funds are transferred to a trustee and subsequently paid by the trustee, not back to the employer for the purpose of dis- charging his obligation, but directly to the employee. ...

29 May 1990 Income Tax Severed Letter AC74750 F- Choix concernant les dividendes en capital- Formule T-2054 Direction des cotisations FROM Section des services et des demandes de DE bilingues renseignements Marc Séguin 957-8973 D.I. ...

En 1979 les corporation X et Y sont fusionnées selon les dis- positions de l'article 87 de la Loi de l'impôt sur le revenu (ci-après "la Loi"). ...

Leung 957-2116 Attention: D.I. Wyse, Chief Trust and SER Assessing Section 7-4413 Capital Dividend Election Subsection 83(2) This memorandum is in response to yours dated October 6, 1989 with respect to the date on which a capital dividend election is made. ...

Reasons: The facts of each case must be examined in order to determine whether the draft provisions could apply to dis-associate a particular corporation from another corporation for SR&ED ITC purposes. ...

The provisions of section 31.1 of The Pension Benefits Act of Manitoba state: "When a garnishee as defined in section 14.1 of The Garnishment Act is served with a garnishing order obtained under that section to enforce a maintenance order against a member of a pension plan, the member is entitled, for the purpose of satisfying the garnishing order and associated costs and taxes, to receive on the day of service, in complete or partial discharge of the member's rights under the plan, an amount equal to the lesser of (a)the amount determined by the formula A- B where Ais the member's pension benefit credit on that day, and Bis the total of all amounts each of which is the portion of the member's pension benefit credit to which another person is entitled on a division thereof under subsection 31(2) as of that day; and (b)the amount determined by the formula C + D + E where Cis the amount specified in the garnishing order Dis the total of all costs allowed by regulation in respect of the garnishing order, and Eis the total of the taxes, if any, that would be required to be deducted or withheld in respect of a payment of the member's entitlement if the amount of the entitlement were determined under this clause. ...

See also the comments of Di Castri in the Law of Vender and Purchaser (2 ed). 5-943255 XXXXXXXXXX Peter Lee (613) 957-8977 Attention: XXXXXXXXXX July 28, 1995 Dear Sirs: Re: Timber Limit Disposition of Timber This is in reply to your letter of December 9, 1994 wherein you requested our comments on circumstances under which a property might be classified as a "timber limit", and on factors in determining whether proceeds from disposition of timber would be on account of income or capital, in light of the Department's positions in Interpretation Bulletins IT-481 and IT-373R. ...