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18 July 1990 Administrative Letter 901146 F- Part XIII Tax on Interest Payments Unedited CRA Tags 212(1)(b)   July 18, 1990 Appeals Branch Financial Institution Appeals and Referrals Division Section   J.P. Dunn   957-8961 Attn. W. Lynn Section Chief 901146   EACC9420 Section:  24(1) We are writing in response to Dave Turner's memorandum of June 25, 1990 concerning the application of paragraph 212(1)(b) of the Income Tax Act (the "Act") 24(1) It is our opinion that, in the circumstances described in your correspondence, Part XIII of the Act is applicable to the interest payments. ...

9 April 1990 Administrative Letter 59766 F- Deferred Salary Leave Plan Unedited CRA Tags 6801(a) 19(1) File No. 5-9766   D.S. ... We suggest that the following comments be made as a 24(1)      "Any such interest paid to a participant under the Plan represents employment income rather than income from property. ... " 3.     The following words should be added at the end of   24(1)      "and the leave of absence must commence immediately after the deferral period. ...

The facts regarding your enquiry as described in your letter are as follows: 1.      ... The peat farming business requires the following steps:-     the scooping of the earth out of bogs,-      the drying of the earth, and-      the screening of the earth. ... Based on the above facts you have asked us to comment on the following: 1.      ...

10 April 1992 Administrative Letter 9206576 F- Employee Profit Sharing Plan- Forfeitures Unedited CRA Tags 144(1) employees profit sharing plan   5-920657   D. ... Delorey   957-8953 April 10, 1992 Registered Plans Division Financial Industries S. ...

18 June 1992 Administrative Letter 9216996 F- Eligible Contributions To Defined Benefit Pension Plan Unedited CRA Tags REG 8502, REG 8516, 147.1(2), 147.2, REG 8501   7-921699   P. Spice   957-8953 June 18, 1992 Registered Plans DivisionFinancial Industries Division Mrs. Stella Kotlar, Director      Eligible Contributions to Defined Benefit Plan We are in receipt of a letter of December 17, 1991, from 24(1) (copy enclosed) which requests your comments on the matters outlined therein.  ...

15 June 1992 Administrative Letter 9214436 F- Use Of T2200 By Employee For Office In Home Unedited CRA Tags 8(13), 8(10), 8(1)(f), 8(1)(h)   921443   A. Humenuk   (613) 957-2134 June 15, 1992 T1 Programs DivisionBusiness and General DivisionAssessment of Returns Directorate Attention: Michelle Desmarais-Markham Office in Home Expense for Employees This is in reply to your memorandum dated May 7, 1992 concerning the interaction of paragraphs 8(1)(f) and 8(1)(i) and subsections 8(10) and 8(13) of the Income Tax Act. ... However, the employee would not be required to submit a form in subsequent years for expenses claimed under paragraph 8(13)(c) which were denied in prior years by reason of paragraph 8(13)(b) since the expenses which are carried forward would have met all the criteria for a deduction in the prior year except for that of paragraph 8(13)(b) of the Act.                            21(1)(b) B.W. ...

18 January 1990 Administrative Letter 59236 F- Payments to Foster Parents Unedited CRA Tags n/a 19(1) File No. 5-9236   J.A. ... Fuoco for DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch c.c.       ... & O.E. Vancouver, D.O. Provincial and International Relations Division ...

27 March 1992 Administrative Letter 9208706 F- Non-Resident- Foreign Exchange Gain Or Loss Unedited CRA Tags 115(1)(b), 39(2)   920870   O. Laurikainen   957-2116 March 27, 1992 J. GauvreauA/DirectorForeign SectionManufacturing Industries, Reorganizations and Partnerships and Trusts DivisionForeign Division Taxation of Foreign Exchange Gains of Non-residents This is with regard to your enquiry whether a non-resident is taxable in Canada on a foreign exchange gain arising on the settlement of a liability denominated in a currency of a country other than Canada.  ...

5 September 1990 Administrative Letter 900846 F- Acquisition of Control on Winding-up Unedited CRA Tags 88(1)(d) 24(1) 900846   M. Vallée   (613) 957-2093   EACC9687 19(1) September 5, 1990 Dear Sirs: Re:  Technical Interpretation Request-  Paragraph 88(1)(d) of the Income Tax Act (the "Act") This is in reply to your letter, dated May 10, 1990, wherein you requested our interpretation of a portion of paragraph 88(1)(d) of the Act in the following hypothetical situation. ...

18 July 1990 Administrative Letter 900916 F- Immigrant's Deductions Unedited CRA Tags 250 19(1) 900916   J.D. Jones   (613) 957-2104   EACC9423 July 18, 1990 Dear Sirs: Re:  Immigrant's Deductions This is in reply to your letter of May 21, 1990, and further to our letter of March 29, 1990, concerning the above noted subject. ...