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3 November 1989 Administrative Letter 74176 F- Assessing Practice Unedited CRA Tags 185(1), 83(2), 130.1(4), 131(1), 152(4), Part III, 185(3)   November 3, 1989 Assessing and Enquiries Directorate Specialty Rulings   Directorate   Firoz Ahmed   957-2092 D.I. Wyse, Chief Your file: HAV 4533-3-4 Trust and SER Assessing Section   File No. 7-4176 Subject: Subsection 185(1) of the Income Tax Act (the "Act") This is in response to your memorandum of July 25, 1989, as supplemented by your memorandum of August 31, 1989, in which you requested our opinion as to the interpretation of subsection 185(1) of the Act. Subsection 185(1) of the Act provides that:      "The Minister shall, with all due dispatch, examine each election made by a corporation in accordance with subsections 83(2), 130.1(4) or 131(1), assess the tax, if any, payable under this Part in respect of the election and send a notice of assessment to the corporation. ...

Specifically you requested that we address the following: 1)      a situation where no assets were acquired and the project was abandoned by the original applicant; 2)     a situation where assets were acquired but not certified and the project was abandoned by the original applicant; 3)     a situation where assets were acquired and certified but no tax credit claimed and the project was abandoned by the original applicant; 4)     a situation where assets were acquired, certified, the tax credit claimed and/or refunded and the project was abandoned by the original applicant. ... Our review of the criteria indicates the following: a)     "approved project"-      the project must have a total capital cost of depreciable property, determined without reference to subsection 13(7.1) or 13(7.4) of the Act, of not less than $25,000,-      the project must have been approved by the Minister of Regional Industrial Expansion pursuant to an application in writing before July 1988.      As it is the project and not the taxpayer which must be approved, in our opinion a transfer of a project from one taxpayer to another at any time during the project would not affect its status as an "approved project". b)     "approved project property"-      the property must be certified by the Minister of Regional Industrial Expansion to be property that has not been used, or acquired for use or lease, for any purpose whatever before it was acquired by the taxpayer.-      the property must met all other criteria contained in the definition of "approved project property" in subsection 127(9) if the Act.       ...

12 December 1989 Administrative Letter 40826 F- Remission of Penalties Unedited CRA Tags n/a   December 12, 1989 TO: VICTORIA DISTRICT OFFICE FROM: HEAD OFFICE G.R. Frolek Technical Interpretations Director Division   Esta Mikhail   (613) 952-3606   File No. 4-0826 SUBJECT:  19(1) 19(1) has written a letter to our Minister dated November 1, 1989 on behalf of 19(1) requesting remission of 24(1) In order that the Remission Committee may be able to consider the request for remission of penalties and apply the guidelines in TOM 2263.22(2)(C), would you kindly submit to this Division a report containing the information required under TOM 2263.24. ... Bernhard BuetowActing DirectorTechnical Interpretations DivisionLegislative & IntergovernmentalAffairs Branch Enclosures ...

Trust to Canadian Beneficiary Unedited CRA Tags Treaty US Article XII, Treaty US Article XIII, Treaty US Article XXI January 6, 1992 MEMO FOR FILE Rulings Directorate   Foreign Section   Jim Wilson   7-913250 Article XII & XIII of the Canada-U.S. ...

5 May 1992 Administrative Letter 9211686 F- Adjustment To Cost Base Unedited CRA Tags 15(1), 56(2), 52(1)   921168   S. Leung   (613)957-2115 May 5, 1992 Audit Technical Support Corporate Reorganizations IIIK. ...

21 October 1992 Administrative Letter 9213056 F- Reimbursement Of Tuition Fees Unedited CRA Tags 6(1)(a)   923105   J.A. Szeszycki   (957-2135) October 21, 1992 MR. READ'S OFFICEAUTHORSUBJECT OR CORPORATE CASE FILE October 21, 1992 MEMORANDUM FOR MR. ...

6 July 1992 Administrative Letter 9219336 F- RRSP Mortgages And Advantages To Annuitant Unedited CRA Tags 146(2)(c.4), 146(8), 146(13.1), REG 4900(1)(j), 204.2   7-921933   D. Duff   957-8953 July 6, 1992 Registered Plans DivisionFinancial Industries DivisionS.M. ...

13 January 1992 Administrative Letter 9129426 F- Deferred Salary Leave Plan Unedited CRA Tags ITA 6801 January 13, 1992 Assessing Directorate Rulings Directorate Enquiries and Taxpayer Deferred Income Plans   Assistance Division   Section Attention:  R. ... Duff   957-8953   7-912942 Deferred Salary Leave Plans: your file HAV 8913-1 This is in reply to your memorandum of October 23, 1991, requesting our opinion on the effect of full and part time employment on the requirement to return to work pursuant to Regulation 6801(a)(v). ...

15 April 1992 Administrative Letter 9208506 F- Clergyman's Residence Housing Allowance Remuneration Unedited CRA Tags 8(1)(c)   920850   R.B. Day   (613) 957-2136 April 15, 1992 Source Deductions DivisionBusiness and General DivisionA. ... Our comments with respect to the two issues set out on page two of the letter, are as follows: 1.      ...

Read   P.D. Fuoco Director General   Personal and Rulings Directorate     General Section Certain Terms Used in the Income Tax Act You asked us to provide you with comments on the occurrence of the following terms in the Act: "family", "spouse", "child(ren)" and "related persons". ...