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2 April 1990 Administrative Letter 59686 F- Impact of 1990 Budget on Withdrawals from RESP Acquired Prior to Budget Date Unedited CRA Tags 146.1, 56(1)(q) 19(1) File No. 5-9686   A.B. Adler   (613) 957-8962 April 2, 1990 19(1) This is in reply to your letter dated February 28, 1990 in which you requested our views concerning the impact of certain budget proposals of February 20, 1990 upon the income tax treatment of withdrawals of income from a registered education savings plan ("RESP") that was acquired prior to that date. ...

18 October 1990 Administrative Letter 901436 F- Subsidiary's Expenditure Year where Transfer of Accounts to Parent on Winding-up Unedited CRA Tags 88(1.3), 88(1)(e.3) 24(1) 901436   L.A. McCarron-McGuire   (613) 957-2092 19(1) October 18, 1990 Dear Sirs: Re:  Technical Interpretation Subsection 88(1.3) of the Income Tax Act (the "Act") We are writing in response to your letter dated July 10, 1990 regarding the omission in paragraph 88(1.3)(a) of the Act of any reference to the subsidiary's "expenditure year". ...

27 February 1990 Administrative Letter 59516 F- Shareholder Debt Benefit Unedited CRA Tags 15(2) 19(1) File No. 5-9516   C. Robb   (613) 957-2744 February 27, 1990 Dear Sirs: Re:  Subsection 15(2) of the Income Tax Act (the "Act") We are writing in response to your letter of January 29, 1990 in which you requested our views concerning subsection 15(2) of the Act and its application where a non-resident corporation connected with a shareholder of a Canadian company ("Canco") collects the accounts receivable of Canco and pays interest to Canco at a prescribed rate on the average monthly balance outstanding. ...

14 February 1990 Administrative Letter 32840 F- Request for Advance Income Tax Ruling Unedited CRA Tags n/a 19(1)                          3-2840                                            J.D. Brooks                                            (613) 957-2097 Dear Sirs: Re: 24(1)      Request for Advance Income Tax Ruling We are writing in response to your letter of November 20, 1989 in which you requested an advance income tax ruling for 24(1) and further to our recent telephone conversations (Brooks) We have completed our initial review of your request and have a number of questions.  ...

14 August 1990 Administrative Letter 900926 F- Payment to Former Independent Contractor Unedited CRA Tags 9 24(1) 900926   J.D. Jones   (613) 957-2104 Attention:  19(1) EACC9315 August 14, 1990 Dear Sirs: Re:  Payment to Former Independent Contractor This is in reply to your letter of May 18, 1990 wherein you requested our opinion on the tax consequences in the following circumstances. 24(1) It is your view that 24(1) Our Comments As discussed with you by telephone, we are unable to provide you with a definitive reply since your question depends primarily on a determination of what the relationship between the tax exempt entity and the individual is in fact. ...

Income Tax Convention on Capital Gains Unedited CRA Tags n/a 19(1) File No. 5-8666   O. Laurikainen   (613) 957-2125 November 20, 1989 Dear Sirs: Re:  Article XIII of the Canada-U.S. ...

Short Ottawa, Ontario (613) 957-2134 K1A 0R2   EACC9483 Attention: Susanne N. ... Subsection 5(1) of the Income Tax Act provides that:      "a taxpayer's income for a taxation year from an office or employment is the salary, wages and other remuneration, including gratuities, received by him in the year". ...

15 March 1990 Administrative Letter 59116- Régime enregistré de pensions- Cotisations pour services passés Unedited CRA Tags 20(1)(s), 146(5)(a), 8(1)(m) 19(1) File No. 5-9116   V. Plant   (613) 957-4796 Le 15 mars 1990 Objet:  Régime enregistré de pensions- Cotisations pour services passés accomplis avant 1990 Monsieur: La présente est en réponse votre lettre du 20 novembre 1989 par laquelle vous demandez notre opinion concernant un fonds de retraite a prestations déterminées que vous désirez implanter. ... Si le contribuable ne rencontre pas les dispositions de l'alinéa 146(5)(a) de la Loi, il pourra avoir droit à une contribution à son R.E.E.R. égale au moindre de 7 500 $ ou de 20% de son revenu gagné.  ...

Laurikainen Development of Audit 927-2116 Programs Division Attention: Dave Burton   900740 Deductible Loss- Section 5903 of the Regulations to the Act This is in response to your memorandum dated May 10, 1990 wherein you requested our opinion concerning the computation of a deductible loss under section 5903 of the Regulations to the Act (the " Regulations") for the purposes of subparagraph 95(1)(b)(v) of the Act in a particular audit case. Our understanding of the facts of the case is as follows: 24(1) 24(1) 1)     No amount is determined under any of clause 5907(1)(c)(ii)(A) or subparagraphs 5907(1)(c)(iii) and (iv) of the Regulations for the purposes of subparagraph 5903(1)(b)(i) of the Regulations in respect of a controlled foreign affiliate of an individual. Such amounts are only determined in respect of a foreign affiliate of a corporation. 2)     Even if a deductible loss had been computed for 24(1) in respect of    24(1)     under subparagraph 5903(1)(b)(i) of the Regulations, such losses would not be deductible in computing the FAPI of    24(1)     The active business losses of a foreign affiliate must generally be incurred by the affiliate in respect of the particular taxpayer claiming them. ...

17 July 1989 Administrative Letter 58286 F- Universal Life Insurance Policies Family Allowances Unedited CRA Tags 148(8) 19(1) File No. 5-8286   J.A. Szeszycki   (613) 957-2130 July 17, 1989 Dear Sirs: Re:  Universal Life Insurance Policies Family Allowances This is in reply to your letter of June 21, 1989, in which you requested confirmation of the tax treatment afforded investment income derived from family allowance payments that are directed into universal life insurance policies. ...