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20 September 1989 Administrative Letter 74326 F- Thin Capitalization Rules- IT-59R3 Unedited CRA Tags 18(4)   September 20, 1989 TO- Publications Division FROM- Specialty Rulings   Directorate Mr. ... Tevlin Director 957-2118   File No. 7-4326 SUBJECT:  Interpretation Bulletin IT-59R3 We are writing to advise you of our concern regarding the comments in paragraph 3 of Interpretation Bulletin IT-59R3 as they relate to the "thin capitalization rules" as determined in subsection 18(4) of the Act. 24(1) 21(1)(a) M.A. ...

19 December 1990 Administrative Letter 903316 F- Reorganization as Part of a Divorce Settlement Unedited CRA Tags 55(3)(a), 248(10) 24(1) 903316   S. Leung   (613) 957-2116 19(1) December 19, 1990 Dear Sirs: Re:  Paragraph 55(3)(a) of the Income Tax Act (the "Act") We are writing further to our letter of March 19, 1990 (file # 5-9293) (the "Letter") which was issued in response to your letter of December 11, 1989 relating to the application of paragraph 55(3)(a) of the Act to a dividend arising in the course of a divorce settlement. ...

The hypothetical facts given are as follows: 1.     Company X is a Canadian corporation which owns the issued common shares of a wholly-owned subsidiary company ("company Y") and the real estate from which company Y conducts certain of its business operations. 2.      ... Company Y also owns a rental apartment building from which it earns net rental income. 4.      ... Factors that are relevant in making such a determination are provided in paragraph 3 of Interpretation Bulletin IT-206R and include (a)     the extent to which the two operations have common factors that say be pertinent, (b)     whether the operations are carried in the same premises, (c)     whether one operation exists primarily to supply the other, (d)     whether the taxpayer's accounting system records the transactions of both operations as if they were those of one business, or whether separate complete set of records are maintained throughout the year. ...

Partner B deals at arm's length with Partner A and Subco. 3.      ... Subco will have no material assets or liabilities, its role being to join with Partner A to create the partnership. 5.      ... Shortly thereafter the partnership's first fiscal year will end. 6.      ...

1 June 1989 Administrative Letter 73876 F- Injury on Duty Pay Unedited CRA Tags 81(1)(h), 56(1)(v), 110(1)(f)(ii), 248(1) death benefit, 248(1) group term life insurance policy, 248(1) pension benefit   June 1, 1989 Scarborough District Office Head Office John H. Rose Small Business and Chief of Enquiries & Office General Division Examination A. Humenuk   (613) 957-2135   File No. 7-3876 Subject: 19(1) We are responding to your memorandum dated April 28, 1989, in which you ask us to respond to the above noted taxpayer's query concerning disability payments payable by his former employer.  ...

21 July 1989 Administrative Letter 89M07206 F- Residence Status of Exempt Organizations Unedited CRA Tags n/a   July 21, 1989 Provincial and International Specialty Rulings Relations Division Directorate   R.C. O'Byrne   957-2126 R.A. D'Aurelio Director Subject: Residence Status of Exempt Organizations 19(1)  have asked whether we would consider an Australian Non-Profit Society (a "Society") to be a resident of Australia for purposes of the Australian Convention. ... We have reviewed Articles 4(1) and 4(2) of the Australian Convention and in our opinion these two provisions could be interpreted to deny treaty protection to a Society in this situation because: 1)     Australian tax law considers a Society of this nature to be resident in and subject to tax in Australia. ...

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. ...

4 September 1990 Administrative Letter 901482 F- Escrowed and Restricted Shares as Investments for RRSPs Unedited CRA Tags 204 qualified investment 24(1) 901482/901576   D. Duff   (613) 957-3498 19(1) EACC9701 September 4, 1990 Dear Madam: This is in response to your letters of June 29 and July 12, 1990 regarding the qualification of escrowed and restricted shares as investments for registered retirement savings plans ("RRSPs"). ...

28 May 1990 Administrative Letter 59646 F- Employee Stock Options Unedited CRA Tags 7 24(1) File No. 5-9646   J.D. Jones   (613) 957-2104 19(1) May 28, 1990 Dear Sirs: Re:  Section 7 of the Income Tax Act (the "Act") This is in reply to your letter of February 21, 1990, wherein you requested a technical interpretation with respect to the application of subsection 7(1.1) of the Act in the following situation. ...

7 September 1989 Administrative Letter 57776 F- Insurance Proceeds Unedited CRA Tags 12(1)(f), 13(21) proceeds of disposition, 56(2) 19(1) File No. 5-7776   J.D. Brooks   (613) 957-2097 September 7, 1989 Dear Sirs: Re:  Paragraphs 12(1)(f) and 13(21)(d) of the Income Tax Act (the "Act") This is in reply to your letter of March 31, 1989 in which you requested our opinion with respect to a situation you described as follows: 24(1) It is apparent that the situation you described relates to specific taxpayers.  ...