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25 October 1989 Ruling AC 45333 F - Attribution and Inter Vivos Transfer Shares of the Capital Stock of a Small Business Corporation

Humenuk Attention: D.I. Wyse 957-2135 Subject: 19(1) Form T2211 We are replying to your memorandum of August 15, 1989, concerning attribution and the inter vivos transfer shares of the capital stock of a small business corporation. ...

29 June 1990 Internal T.I. 7901287 F - Retirement Compensation Arrangement ("RCA")

Delorey 957-3495 Attention: D.I. Wyse Returns Processing Division File No. 7-901287 Subject: Retirement Compensation Arrangement ("RCA") 24(1) Attached is a copy of a referral from the Kitchener District Office concerning a taxpayer who claims to have inadvertently made a contribution to a "statutory arrangement" deemed to have been established on January 1, 1988 ("deemed RCA"). ...

9 June 1989 Internal T.I. 73899 F - Capital Dividend Elections

Leung 957-2116 D.I. Wyse Chief File No. 7-3899 Subject: Capital Dividend Elections Subsection 83(2) of the Income Tax Act (the "Act")- Form T2054 This is in reply to your memorandum dated May 9, 1989 with respect to the above-noted subject matter. ...

13 July 1990 Ruling ACC9233 F - Review of Form T212

D.I. Syse Technical Publications Chief of Trusts and SER Division Assessing Section Mary Evans 957-9229 EACC 9233EACC 9233 Review of form T212 We have reviewed Form T212. ...

25 October 1989 Income Tax Severed Letter AC4533 - Attribution and Inter Vivos Transfer Shares of the Capital Stock of a Small Business Corporation

Legault, Director Attention: D.I. Wyse From: Business and General Division A. ...

29 January 1990 Income Tax Severed Letter AC746177 - Validity of Election to Transfer Shares to Trust of Minor (T2211)

Harding (613) 957-3499 Attention: D.I. Wyse, Chief Trust and SER Assessing Section 7-4617 Your file: HAV 4533-3 PC JL221-1 Validity of T2211 Subsection 73(5) This is in reply to your memorandum of January 3, 1990 wherein you requested our opinion on the validity of an election to transfer shares to the trust of a minor under the provisions of subsection 73(5) of the Income Tax Act (the Act). ...

11 January 1990 Income Tax Severed Letter AC745847 - Due Date for Form T2059

Vallée 957-2093 D.I. Wyse Chief 7-4584 Due Date for Form T2059- Subsection 96(4) of the Income Tax Act (the "Act") Your file HAV 4533-3-18 PC J1211-1 This is in reply to your memorandum dated December 13, 1989, whereby you request our opinion regarding the due date for making an election pursuant to subsection 97(2) of the Act, as determined by subsection 96(4) of the Act in the following situation. ...

19 April 1990 Income Tax Severed Letter AC74812 - Meaning of "Capital Dividend Account" of a Corporation

19 April 1990 Income Tax Severed Letter AC74812- Meaning of "Capital Dividend Account" of a Corporation APRIL 19 1990 Assessing & Enquiries Directorate Specialty Rulings Directorate Firoz Ahmed 957-2092 Attention: D.I. ...

Abel v. R., [1997] 1 CTC 2016 (Informal Procedure)

Issue The issue is whether the Minister of National Revenue properly dis allowed the appellant’s claims for carrying charges for the 1990, 1991 and 1992 taxation years in the amounts of $10,625.00, $8,911.00 and $6,787.00 respectively. ...

Burkart v. R., [1999] 1 CTC 2371, 99 DTC 178

Item Fees Disbursem Bl(l)(a) Services prior to ex $ 300.00 amination for dis covery Bl(l)(b) Status hearing of $ 300.00 June 4, 1996, Ad journed; held Janua ry 20, 997 Bl(l)(b) Motion dated April $ 300.00 21, 1997 heard by conference call June 12, 1997 Bl(l)(b) Motion dated June $ 300.00 27, 1997 with writ ten representations Bl(l)(b) Examination for $ 600.00 Discovery held Sep tember 8 and 9, 1997 in Ottawa Bl(l)(b) Motion dated Sep $ 300.00 tember 23, 1997 Bl(l)(b) Taxing costs $ 300.00 Bl(l)(c) Preparation for $ 400.00 hearing Bl(l)(d) Conduct of hearing $1,000.00 Bl(l)(e) Services after Judg $ 200.00 ment Bl (2) Costs of Transcript $1,878.39 of Examination for Discovery held on September 8 & 9, 1997 Total Fees $4,000.00 Total Disbursements $1,878.39 Subtotal At the outset, Mr. ...

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