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Office Y.S. 9226008 Central Records Author / Section Chief District Office? Research File Taxpayer's File Return to Specialty Rulings, Room 303, Met.   ... Yours sincerely, Otto Jelinek c.c:      The Honourable Don Mazankowski, Deputy Prime Minister, President of the Queen's Privy Council for Canada and Minister of Agriculture G. ...

Or, The 0xford English Dictionnary (2e édition) le définit comme suit:      agent-general, The official representative of a non-sovereign country or state in the capital city of a sovereign state; [specifically] a representative of: (i) the British Crown Colonies (also the Dominion of Canada) in London; (ii) an Australian state or Canadian (...) ... À     partir de cette définition 24(1).../2 24(1) Nous espérons que nos commentaires vous seront utiles et nous vous prions d'agréer l'expression de nos sentiments distingués. ...

9 March 1990 Ministerial Letter 74688 F- Attribution of Trust Income or Loss to Settlor of Trust Unedited CRA Tags 75(2)   DATE:  March 9, 1990 TO:  CALGARY  DISTRICT OFFICE FROM:  HEAD OFFICE   Rulings Directorate Attention:  Ross Brown Financial Institutions Section Section Chief- Trust Section M.M. Trotier   (613) 957-8957   FILE No.  7-4688 SUBJECT: 24(1) We have recently been advised by 19(1) that your district office will be reviewing the income tax returns of  24(1) and its related trusts. ...

19 March 1990 Ministerial Letter F3538 F- Annual Review of IC 78-5R2 Re Communal Organizations Unedited CRA Tags n/a   March 19, 1990 Enquiries and Taxpayer Current Amendments and Assistance Division Regulations Division   N.M. ... McNally 957-2079 Director   File No. F-3538 Annual Review of Inf. Cir. 78-5R2 Communal Organizations This is in reply to your memorandum of February 14, 1990 concerning the above. ...

30 October 1989 Ministerial Letter 89M10508 F- Tax Remission Request Unedited CRA Tags n/a   October 30, 1989 TO- OTTAWA DISTRICT OFFICE FROM- HEAD OFFICE P. Middlestead Technical Interpretations Director- Taxation Division   D. Lanos   957-9231 SUBJECT: Tax Remission Request 19(1) Further to your memorandum of April 19, 1989, enclosed is a copy of the Minister's reply of October 18, 1989 to Ms. ...

21 December 1989 Ministerial Letter 58678 F- Wage Loss Replacement Plans Unedited CRA Tags n/a 19(1) 5-8678   A. ... the actual documentation of the programme indicates that the employees are required to pay 100% of the cost of the plan, 2.     the premium which is remitted by the employer is added to the employee's income in the manner of salary and wages paid at the time the premium is paid, and 3.      ...

6 July 1989 Ministerial Letter 58258 F- Deferred Salary Leave Plan Unedited CRA Tags 6801 19(1) File No. 5-8258   W.C. Harding   (613) 957-3499 July 6, 1989 Dear Sirs: Re:  Deferred Salary Leave Plan (the "Plan") This is in reply to your letter of June 6, 1989, referred to us by our Assessing Directorate, requesting a ruling in respect of the above noted plan for the purposes of the definition of salary deferral arrangements. ... As a consequence thereof, the Plan should be amended to give the employee the right to withdraw funds only in the case of financial or other hardship. 3.      ...

17 December 1990 Ministerial Letter 901278 F- Voluntary Payments of Interest on Loans Unedited CRA Tags 80.4, 20(1)(c) 24(1) 901278   A. Humenuk   (613) 957-2135 19(1) December 17, 1990 Dear Sirs: Re:  Section 80.4 of the Income Tax Act (the "Act") This is in reply to your letter of June 11, 1990, wherein you requested our views on whether voluntary payments of interest would be considered to be interest paid for the year on a loan which bears no interest or bears interest at a rate lower than the prescribed rate for purposes of paragraphs 80.4(1)(c) and 80.4(2)(e) of the Act. ... However, the Department is still prepared to accept that a timely voluntary payment by an employee to his employer is interest for the purpose of the calculation under section 80.4 provided that: a)     the employer reports the payment as interest income, b)     there is an actual payment by the employee, that is, no journal transfer or exchange of cheques, and c)     the other conditions of section 80.4 are met. ...

19 December 1990 Ministerial Letter 902918 F- Shares Issued to Avoid Tax Unedited CRA Tags 95(6), 93(4), 5905(8) 24(1) 902918   O. Laurikainen   (613) 957-2129 19(1) December 19, 1990 Dear Sirs: Re:  Subsection 95(6) of the Income Tax Act (the "Act") This is in response to your letter of October 18, 1990 wherein you requested clarification of the application of subsection 95(6) of the Act in the context of the following fact situation. 1.     Corporation A is a taxable Canadian corporation. 2.     Corporation B is a non-resident corporation which is not a foreign affiliate of corporation A nor is it controlled, directly or indirectly in any manner whatever, by corporation A or by a related group of which corporation A is a member. 3.      ...

Our understanding of the hypothetical situation is as follows: 1.      ... Active business has the meaning assigned by paragraph 125(7)(a) of the Act. 3.      ... A Co. will secure its unpaid amount against assets of the partnership. 7.      ...