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Technical Interpretation - External
3 March 2000 External T.I. 2000-0007885 - DIS. T.C.&MED EXP. FOR INSTITU. FEES
3 March 2000 External T.I. 2000-0007885- DIS. T.C.&MED EXP. FOR INSTITU. ...
Technical Interpretation - External
25 May 2000 External T.I. 2000-0013055 - CONTRACT PAY.&REPORTING SYSTEM-WASTE DIS.
&REPORTING SYSTEM-WASTE DIS. Unedited CRA Tags 238(1) 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. ...
Technical Interpretation - External
21 August 1991 External T.I. 9018685 F - Interest Deductibility
In this regard, Di Castri states the following: Prima facio, 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. [FN: 3 Victor Di Castri, The Law of Vendor and Purchaser, 3rd ed. ...
Technical Interpretation - External
25 June 1990 External T.I. 74785 F - Capital Dividends Elections
25 June 1990 External T.I. 74785 F- Capital Dividends Elections Unedited CRA Tags 83(2), 184 June 25, 1990 Assessing and Enquiries Directorate Rulings Directorate D.I. ...
Technical Interpretation - External
4 April 1990 External T.I. 74810 F - Employee Savings Plan
Adler (613) 957-8962 Attention: D.I. Wyse, Chief Trust and S.E.R. Assessing Section File No. 7-4810 SUBJECT: Employee Savings Plans 24(1) Your File: HAV 9586-1 This is in reply to your memorandum dated March 14, 1990 in which you requested our views concerning a proposed non-registered portfolio of funds to be established by 24(1) for the investment of after-tax funds of certain employees. 19(1) indicated that in theory the fund operates in a manner similar to that of a mutual fund. ...
Technical Interpretation - External
6 June 1990 External T.I. 5900585 F - RRSP - Transfer to New Trustee
Delorey 957-3495 Attention: D.I. Wyse T3 Assessing File No. 5-900585 SUBJECT: Registered Retirement Savings Plan ("RRSP") Transfer to New Trustee Attached is a copy of a letter from 24(1) signed by 19(1). ...
Technical Interpretation - External
29 August 1989 External T.I. 74100 F - Prescribed Forms to be Filed by Transferors and Transferee
Leung Director 957-2116 Returns Processing Attention: D.I. Wyse File No. 7-4100 Subject: Prescribed forms required to be filed pursuant to subsections 85(1), 85(2), 97(2) and 98(3) This memorandum is in response to yours dated July 6, 1989 with respect to the above-referenced prescribed forms. ...
Technical Interpretation - External
20 November 1989 External T.I. 74205 F - Canada-U.S. Income Tax Convention on Capital Gains
Di Libero O.S. Laurikainen (613) 957-2125 File No. 7-4205 SUBJECT: Article XIII (9) of the Canada-U.S. ...
Technical Interpretation - External
28 July 1995 External T.I. 9432555 - TIMBER LIMIT AND DISPOSITION OF TIMBER
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. ...