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4 January 1990 Administrative Letter 32706 F- Advance Income Tax Ruling Request- September 19, 1989 Unedited CRA Tags n/a 19(1) File No. 3-2706   R.B. Day   (613) 957-2136 January 4, 1990 Dear 19(1) Re:  24(1) Advance Income Tax Ruling Request- September 19, 1989 We are writing with respect to the above-noted ruling request and further to our telephone conversation of November 14, 1989. ...

23 March 1990 Administrative Letter 59706 F- Forgiveness of Debt under a Will Unedited CRA Tags 105(1), 80(1)(h) 19(1) File No. 5-9706   D.S. Delorey   (613) 957-3495 March 23, 1990 Dear Madam: This is in reply to your letter of March 5, 1990 requesting our views on whether or not subsection 105(1) of the Income Tax Act (the "Act") applies where a debt is forgiven under a will. ...

14 December 1990 Administrative Letter 903296 F- Transfer of Property to Corporation by Shareholders Unedited CRA Tags 85(1), 110.6(1) qualified small business corporation share 24(1) 903296   M.P. Sarazin   (613) 957-2125 19(1) December 14, 1990 Dear Sirs: Re:  Subsection 85(1) of the Income Tax Act (Canada) (the "Act") We are writing in response to your letter of November 19, 1990 wherein the situation described is identical to the one described in your letter of October 30, 1990 except for the additional statement that one share qualifies as a qualified small business corporation share, as that term is defined in subsection 110.6(1) of the Act, and the other does not qualify. ...

15 May 1990 Administrative Letter 900576 F- Indian Band Councils Regarded as Canadian Municipalities Unedited CRA Tags 118(1)(d) 24(1) File No. 900576   Bill Guglich   (613) 957-2102 19(1) May 15, 1990 Dear Sirs: This is in reply to your letter of December 13, 1989 concerning the 24(1) position as set out in paragraph 11 of Interpretation Bulletin IT-62 is that band councils that have reached the advanced stage of development required by Section 83 of the Indian Act will be regarded as Canadian municipalities for purposes of paragraph 118(1)(d) of the Income Tax Act. ...

28 March 1990 Administrative Letter 59616 F- Recruitment Payments to Donors Unedited CRA Tags 3 19(1) File No. 5-9616   J.D. Jones   (613) 957-2104 March 28, 1990 Dear Sirs: Re: Recruitment Payments to Donors This is in reply to your letter of February 5, 1990, addressed to the Winnipeg District Taxation Office regarding the above-noted subject which has been referred to this office for reply. ...

29 March 1990 Administrative Letter 59566 F- Food and Entertainment Expenses Limitation Unedited CRA Tags 67.1(2)(e) 19(1) File No. 5-9566   J.D. Jones   (613) 957-2104 March 29, 1990 Dear Sirs: Re:  80% Food and Entertainment Expense Limitation Paragraph 67.1(2)(e) of the Income Tax Act (the "Act") This is in reply to your letter of February 6, 1990, wherein you requested we review the information concerning the interpretation of paragraph 67.1(2)(e) of the Act as set out in our previous letter of June 6, 1989, and provide you with any updated comments. ...

4 July 1989 Administrative Letter 58056 F- Lease Unedited CRA Tags n/a 19(1) File No. 5-8056   Peter Lee   (613) 957-2745 July 4, 1989 Dear Sir: Re:  Lease We are writing in reply to your letter of May 10, 1989, wherein you requested our opinion with respect to a "lease" with a "guaranteed residual value" clause. ...

13 June 1989 Administrative Letter 32356- Demande de décisions anticipées Unedited CRA Tags n/a 19(1) File No. 3-2356   Charles Thériault   (613) 957-8984 Le 13 juin 1989 Monsieur, Objet:  24(1) Demande de décisions anticipées La présente fait suite à notre conversation téléphonique (Thériault 19(1)) du 2 juin 1989, relativement au retrait de votre demande de décisions anticipées du 21 février 1989 pour le compte des contribuables mentionnés plus haut.  ...

20 November 1989 Administrative Letter 59076 F- Availability of a Rollover of Real Property Inventory into a Partnership Unedited CRA Tags 97(2) 19(1) File No. 5-9076   R. Albert   (613) 957-2098 November 20, 1989 Dear Sirs: Re:  Subsection 97(2) of the Income Tax Act (the "Act") We are writing in reply to your letter of November 20, 1989 wherein you requested written confirmation of the availability of a rollover of inventory which is real property into a partnership.  ...

However, as stated in IT 449R at paragraph 7, where a property is transferred to a spouse pursuant to a court order given under a statute such as a family law act, paragraph 70(6)(a) of the Act may apply to the transfer if the court order is made within 36 months after the death of the deceased or such longer period as is reasonable, provided the requirements for extending the period, as discussed in IT 449R, are complied with.      ...