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Tang (613) 957-2103 ATTENTION Don Drohan Enquiries & Office Examination RE: Legal Fees This is in reply to your recent memorandum wherein you request our comments concerning the deductibility of legal fees incurred by a taxpayer to collect "wage loss replacement benefits" from an insurance company. ...

We have not examined the printout entitled "Masterplan & Your Retirement with a RCA" which was attached to your letter and make no comments as to whether its illustration of the operation of the refundable tax account is accurate. ...

Original signed by Chief Merchandising & Manufacturing Section Corporate Rulings Division Legislation Branch ...

". It would, therefore, appear that the copyrights and the exhibition rights would have to be valued separate from the tangible property donated. ...

" Paragraph 1(a) of Article 2 of the former Canada-United Kingdom Income Tax Agreement states that: "the term "United Kingdom" means Great Britain and Northern Ireland, including any area outside the territorial waters of the United Kingdom which has been designated, under the laws of the United Kingdom concerning the Continental Shelf, as an area within which The rights of the United Kingdom with respect to the sea-bed and sub-soil and their natural resources may be exercised;" While both the Convention and the Agreement contain clauses which permit an extension of these treaties to any ".. territory for whose international relation either of the Contracting Governments is responsible... ...

Massel, Director Accounting & Collections Division ...

The term "retiring allowance" is defined by subsection 248(1) of the Income Tax Act as "... an amount received upon or after retirement from an office or employment... ...

Chief Services, Public Utilities & Exempt Corporations Section Corporate Rulings Division Legislation Branch ...

Chief Leasing & Financing Section Financial Industries Division Rulings Directorate ...

18 April 1980 Income Tax Severed Letter 7-737- [Sale of undivided interest upon cessation of partnership] April 18, 1980 HAMILTON DISTRICT OFFICE Chief of Verification & Collections M. ...