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31 October 1989 Administrative Letter 58576 F- Transfer of Unused Credit to Spouse Unedited CRA Tags 118(1)(c) 19(1) File No. 5-8576   A. Humenuk   (613) 957-2135 October 31, 1989 Dear Sir: Re:  Transfer of Unused Credits to Spouse We are responding to your letter of August 29, 1989, concerning the transfer of the unused portion of your pension tax credit to your spouse. ...

29 March 1990 Administrative Letter 32926 F- Transfer to Spouse Trust Unedited CRA Tags 70(6) 24(1) File No. 3-2926   J.A Szeszycki   (613) 957-2103 March 29, 1990 Dear Sirs: Re:  Request for Income Tax Ruling We are responding to your letter of December 20, 1989, requesting an advance income tax ruling. ...

21 September 1989 Administrative Letter 58696 F- Paragraph 55(3)(b) of the Act Unedited CRA Tags 55(3)(b), 55(2) 19(1) File No. 5-8696   H.K. Tilak   (613) 957-2122 September 21, 1989 Dear Sirs: Re:  Paragraph 55(3)(b) of the Income Tax Act We are writing in response to your letter of September 13, 1989 requesting the Department's views regarding the circumstances in which a particular liability is considered to relate to a particular asset of a corporation in determining the net fair market value of each type of property for the purposes of a "net" butterfly of the property of that corporation in the course of a reorganization that forms part of a series of transactions or events to which subsection 55(2) of the Income Tax Act (the Act) would, but for paragraph 55(3)(b) of the Act, apply. ...

22 May 1990 Administrative Letter 59226 F- Joint Ventures Unedited CRA Tags n/a 24(1) File No. 5-9226 (900009)   J.D. Brooks   (613) 957-2097 19(1) May 22, 1990 Dear Sirs: Re:  Joint Ventures We are writing in response to your letter of November 1, 1989 in which you requested our opinions regarding the application of the Income Tax Act (the "Act") to joint ventures. ...

26 February 1990 Administrative Letter 59546 F- Capital Gains Derived by Mutual Fund Trust Unedited CRA Tags 132(6), 108(2) 19(1) File No. 5-9546   D.S. Delorey   (613) 957-3495 February 26, 1990 Dear Madam: This is in reply to your letter of October 16, 1989, received in this office on February 9, 1990, and further to our (Delorey 19(1)) telephone conversations on February 15 and 16, 1990. ...

Our understanding of the situation set out in your letter and clarified during our telephone conversation of April 10,1991, is as follows. 24(1) With respect to the pension fund contributions, redirected through the  24(1) of the pension plan, you have analysed the possible income tax consequences for employer pay-all and employee pay-all wage loss replacement plans if the employer 24(1) were to self-fund these pension plan contributions. 1.      ... Because the payment of the plan premiums by the employer does not create a taxable benefit to the employees and since the LTD benefits are taxable in the hands of the recipients, this arrangement would, in your view, have no adverse income tax implications for the employees. 2.      ...

6 November 1989 Administrative Letter 58396 F- Automobile Allowances Unedited CRA Tags 6(1)(b)(v), 18(1)(r) 19(1) File No. 5-8396   S. Short   (613) 957-2134 November 6, 1989 Dear Sirs: Re:  Automobile Allowances This is in reply to your letter dated July 14, 1989, wherein you have requested an interpretation of subparagraph 6(1)(b)(v) and paragraph 18(1)(r) of the Income Tax Act (the "Act") in connection with the following situation: A commission based employee receives an automobile allowance that is in excess of 27 cents for the first 5,000 kilometres and 21 cents for the remaining kilometres.  ...

15 February 1990 Administrative Letter 59456 F- Gift of Capital Property Unedited CRA Tags 118.1(6) 19(1) File No. 5-9456   J.D. Jones   (613) 957-2104 February 15, 1990 Dear Sirs: Re:  Subsection 118.1(6) of the Income Tax act (the "Act") This is in reply to your letter of January 24, 1990, and further to our letter of January 18, 1990, regarding the above-noted subject. ...

22 September 1993 Administrative Letter 9326116 F- Legal Fees to Secure Wage Loss Benefit From Insurer Unedited CRA Tags 6(1)(f), 8(1)(b)   Client Assistance Directorate Personal and General Hélène Beauchemin Section Director General Attention:  Jeff Shaver Deductibility of Legal Fees Your file: 93-4272T XXXXXXXXXX We are replying to your memorandum of September 8, 1993 in which you ask whether legal fees incurred to re-establish the taxpayer's rights to benefits under a wage loss replacement plan are deductible. As indicated in paragraph 1 of Interpretation Bulletin IT-99R4, legal fees are only deductible to the extent that they a)     are incurred for the purpose of gaining or producing income from a business or property and b)     are not outlays of a capital nature unless such fees are specifically provided for by a provision of the Act. ...

Plus de 80 % des bulletins existants ont déjà fait l'objet d'une ou de plusieurs mises à jour. ... Two new series of publications were introduced for this purpose – Interpretation Bulletins and Information Circulars – to cover the interpretative and the administrative positions, respectively, in the Assessing Guide and Information Bulletins. ... Other sections of the Income Tax Rulings & Interpretation Directorate may also prepare some bulletins. ...