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13 December 1989 Ministerial Letter 59168 F- Taxation of Employee Benefit Plan Beneficiaries at Death Unedited CRA Tags 6(1)(g), 56(1)(a)(i), 70(2), 70(3) 19(1) 5-9168   W.C. Harding   (613) 957-3499 December 13, 1989 Dear Sirs: Re:  Employee Benefit Plans ("EBPs")  Purchase of annuities This is in reply to your letter of November 24, 1989, in respect of the taxation of EBP beneficiaries at death, when they have previously elected to have their EBP benefits paid to them through an annuity purchased and held by the Plan trustee. ...

28 December 1989 Ministerial Letter 58988 F- Recaptured of CCA Unedited CRA Tags 125(7) specified investment business, 129(6) 19(1) 5-8988   R.B. Day   (613) 957-2136 December 28, 1989 19(1) We are writing in reply to your letter of October 26, 1989, wherein you requested our views regarding the income tax implications of the recapture of capital cost allowance ("CCA") relative to subsection 129(6) of the Income Tax Act, in the following scenario. ...

14 September 1989 Ministerial Letter 74208 F- RRSP Unedited CRA Tags 146(8.1) 19(1) File No. 7-4208   D.S. Delorey   (613) 957-3495 September 14, 1989 Your letter of June 23, 1989 addressed to the Sudbury Taxation Centre has been forwarded to this Division for reply. ...

30 January 1990 Ministerial Letter 59158 F- Meaning of "Invariant" and "Invariable" Unedited CRA Tags 5100(2)(b)(iii) 19(1) File No. 5-9158   A.B. Adler   (613) 957-8962 January 30, 1990 Dear Sirs: This is in reply to your letter dated November 27, 1989 in which you requested our views concerning the meaning of the words "invariant" and "invariable" as used in the English and French versions respectively of subparagraph 5100(2)(b)(iii) of the Income Tax Regulations ("Regulations") and provided two examples for our use. ...

Estate Tax Unedited CRA Tags n/a 24(1) 902998   G. Arsenault   (613) 957-2126 19(1) December 10, 1990 Re:  Canada-United States income Tax Convention, 1980 (the "Convention")- U.S. ...

18 August 1989 Ministerial Letter 58408 F- Debtor's Gain on Settlement of Debt Unedited CRA Tags 80(1), 88(1), 87(7), 69(1) 19(1) File No. 5-8408   A.A. Cameron   (613) 957-2115 August 18, 1989 Dear Sirs: Re:  Subsection 80(1) and 88(1) of the Income Tax Act (Canada) (the "Act") We are writing in response to your letter of July 21, 1989 in which you requested a technical interpretation with respect to the application of subsections 80(1)and 88(1) of the Act. ...

17 October 1990 Ministerial Letter 900848 F- Election Re Value of Inventory of Artistic Endeavour Unedited CRA Tags 10(6), 70(2), 70(3), 69(1.1) 24(1) 900848   R.B. Day   (613) 957-2136 19(1) October 17, 1990 Dear Sirs: Re:  Subsection 10(6) Election This is in reply to your letter of May 14, 1990, wherein you requested our opinion on the income tax consequences to a deceased artist who bequeathed his inventory of art to a person with whom he dealt with at arm's length. ...

19 September 1990 Ministerial Letter 901448 F- Conversion of Bank Debentures to Deposits Constituting Disposition Unedited CRA Tags 54 disposition 24(1) 901448   J.P. Dunn   (613) 957-8961 19(1) EACC9642 September 19, 1990 19(1) This is in response to your correspondence of June 25, 1990 requesting a technical interpretation with regards to a situation wherein bank debentures are converted to deposits payable on a fixed date and, more specifically, whether such conversion would constitute a disposition for purposes of the Income Tax Act (the "Act"). ...

28 May 1990 Ministerial Letter 900378 F- Provision of Benefit from Single Purpose Corporation Unedited CRA Tags n/a 24(1) File No. 900378   C.R. Brown   957-2082 19(1) May 28, 1990 Dear Sirs: This is in reply to your letter of March 26, 1990 concerning a "single purpose corporation". ...

21 March 1990 Ministerial Letter 59698 F- Benefits under Family Trust- Ownership of Recreational Property Unedited CRA Tags 105, 105(1), 105(2) 19(1) File No. 5-9698   A.B. Adler   (613) 957-8962 March 21, 1990 Dear Sirs: This is in reply to your letter dated February 12, 1990 in which you requested our comments with respect to the application of section 105 of the Income Tax Act ("Act") in specified circumstances involving the ownership of recreational property by a family trust. ...