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July 18, 1989 # 293 3-2323 D.J. Lightheart (613) 957-9795 XXX July 18, 1989 Dear Sirs: Re: XXX XXX Our comments Information Circular 70-6R states that the purpose of an advance income tax ruling is to inform a taxpayer of how the Department of National Revenue (the "Department") will interpret specific provisions of the law in respect of a definite transaction or transactions. ...

Yee 920896 Award for wrongful dismissal This is in reply to your round trip memorandum of March 16, 1992 in which you have asked for our comments with regards to the tax implications of the XXX The relevant facts can be summarized as follows: XXX Our comments Subparagraph 56(1)(a)(ii) of the Income Tax Act (the 'Act') states that: "Without restricting the generality of section 3, there shall be included in computing the income of a taxpayer for a taxation year, (a) any amount received by a taxpayer in the year as, on account or in lieu of payment of, or in satisfaction of, (...) ...

Farrell Chief of Verifications & Collections Revenue Canada, Taxation Mississauga District Taxation Office P.O. ...

SUBJECT: ESTATE FREEZE SECTION: 55(3)(a), 55(2)] April 28, 1992 PRAIRIE TAX CONFERENCE DRAFT/EBAUCHE May 19 & 20, 1992 Question 24 Mr. ...

File # 7-920766. See also March 27, 1992 memo from the Foreign Section to J. ...

(7984-1) SECTION: 122.3] May 1,1992 Assessing & Accounting Programs Section K. ...

Paragraph 6 of the Convention provides that the term "earnings" for the purposes of determining branch tax: "... does not include profits attributable to a permanent establishment in Canada of a company which is a resident of Switzerland earned in a year during which the business of the company was not carried on principally in Canada. ...

AUTHOR SECTION CHIEF D.O. (?) RESEARCH FILE SUBJECT OR CORPORATE CASE FILE XXX I am responding to your letter of March 17, 1992, in which you asked for confirmation of the correct tax treatment of payments that will be received by individuals pursuant to the recently enacted Centennial Flame Research Award Act. ...

July 17, 1989 # 291 5-8225 G. Ozols (613) 957-2127 XXX July 17, 1989 Dear Sirs: Re: Professional and Occupational Association Registration Act (Alberta) This is in reply to your letter of June 14, 1989, concerning the deduction of professional dues under subparagraph 8(1)(i)(i) of the Income Tax Act (the "Act"). ...

In addition subparagraph 111(5)(a) (ii) refers to "... similar properties or the rendering of similar services". ...