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27 March 1990 Administrative Letter 59726 F- Deferred Salary Leave Plan- Withholding of CPP, UIC and Income Tax Unedited CRA Tags n/a 19(1) File No. 5-9726   Maureen Shea-DesRosierss   (613) 957-8953 March 27, 1990 Dear Sirs: Re: Deferred Salary Leave Plan ("DSLP") Withholding of Canada Pension Plan ("CPP") Unemployment Insurance ("UI") and income tax This is in reply to your letter of March 2, 1990 wherein you request information concerning the above-mentioned subject. ...

4 July 1989 Administrative Letter 58156 F- Employee Benefit Plan Unedited CRA Tags 153(1)(a), Part 1, 115(1)(a) 19(1) File No. 5-8156   W.C. Harding   (613) 957-3499 July 4, 1989 Dear Sir: Re: Employee Benefit Plan ("EBP") This is in reply to your letter of May 25, 1989 wherein you requested our comments on the taxation of payments out of an EBP to a resident of the United States. ...

23 August 1990 Administrative Letter 901466 F- Employees Profit Sharing Plan- Employee Leaving in Middle of the Year Unedited CRA Tags 144, 2(3), 6(1)(d), 115 24(1) 901466   Maureen Shea-DesRosierss   (613) 957-8953 Attention: 19(1) EACC9276 August 23, 1990 Dear Sirs: Re: Employees Profit Sharing Plan ("EPSP") Section 144 of the Income Tax Act (the "Act") This is in reply to your letter of June 21, 1990 concerning the above-mentioned subject. ...

18 June 1990 Administrative Letter 59786 F- Stock Options Granted to Non-residents Unedited CRA Tags 7 24(1) File No. 5-9786   J.D. Jones   (613) 957-2104 Attention: 19(1) June 18, 1990 Dear Sirs: Re:  Stock Options Granted to Non-Residents This is in reply to your letter of March 19, 1990, wherein you requested our opinion on the applicability of section 7 of the Income Tax Act in the following situation. ...

14 November 1989 Administrative Letter 58506 F- Meaning of Replacement Property Unedited CRA Tags 44(5) 19(1) File No. 5-8506   M. Eisner   (613) 957-2138 November 14, 1989 Dear Sirs: This is in reply to your letter of August 4, 1989 concerning the meaning of "replacement property" in subsection 44(5) of the Income Tax Act. ...

19 April 1990 Administrative Letter 59756 F- Registered Pension Plan Unedited CRA Tags 8(1)(m), 111(1)(a), 111(8) non-capital loss 19(1) File No. 5-9756   A.B. Adler   (613)957-8962 April 19, 1990 Dear Sirs: This is in reply to your letter dated March 13, 1990 in which you requested our views whether certain payments from an insurance company to a registered pension plan ("RPP") would constitute contributions thereto for purposes of paragraph 8(1)(m) of the Income Tax Act ("Act") in the following situation. 24(1) It is not our practice generally to provide written opinions concerning actual and/or completed transactions, however, we are prepared to provide you with the following comments. ...

12 January 1990 Administrative Letter 59106 F- Non-resident Withholding Tax Unedited CRA Tags Part XIII 19(1) File No. 5-9106   A. Seidel   (613) 957-8960 January 12, 1990 Dear Sir: This is in reply to your letter of November 17, 1989 and further to our conversation of December 8, 1989 with respect to the withholding of tax pursuant to Part XIII of the Income Tax Act (the "Act") where a non-resident corporation in one country uses a Canadian bank as its agent to make interest or dividend payments to a non-resident in another country. ...

7 June 1990 Administrative Letter 59396 F- Taxable Capital Employed in Canada of Financial Institution Unedited CRA Tags 181.3(1)(a) 24(1) File No. 5-9396   J.P. Dunn   (613) 957-8961 19(1) June 7, 1990 Dear Sir: We are writing in response to your correspondence of January 11, 1990 requesting our interpretation of the phrase "an asset of the financial institution that is tangible property used in Canada" as that term is utilized in draft paragraph 181.3(1)(a) of the Income Tax Act dealing with the proposed Tax on Large Corporations. ...

14 July 1989 Administrative Letter 57786 F- Deductibility of Union Dues Unedited CRA Tags 8(1)(i)(iv), 8(5), 56 19(1) File No. 5-7786   S. Short   (613) 957-2134 July 14, 1989 Dear Sirs: Re:  Deductibility of Union Dues This is in reply to your correspondence dated March 30, 1989, wherein you have queried the deductibility of union dues paid by 24(1) retirees for income tax purposes. ...

3 December 1990 Administrative Letter 903016 F- Private Corporation Status under Canada-Germany Income Tax Convention Unedited CRA Tags n/a 19(1) 903016   M.P. Sarazin   (613) 957-2125 December 3, 1990 Dear Sir: Re:  Article 13 of the Canada-Germany Income Tax Agreement (1981) (the Agreement) We are writing in reply to your letter dated October 18, 1990 wherein you brought to our attention the fact that the assumption made in our letter dated August 14, 1990 that the West-German "Gesellschaft des buergerlichen Rechts" ("GbR") is a private corporation is not correct. ...