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Miscellaneous severed letter
26 March 2003 Income Tax Severed Letter 2002-0012557 - Tuition credit dentistry equipment fees
Paragraph 26 of Interpretation Bulletin, Tuition Tax Credit () states that charges for use of library or laboratory facilities, whether identified separately or included as course or subject fees are considered eligible tuition fees. ...
Miscellaneous severed letter
15 January 1992 Income Tax Severed Letter 260
Day (613) 957-2136 XXX January 15, 1992 Dear XXX Re: Subsection 74.1(2) of the Income Tax Act (the Act) We are writing in reply to your letter of November 11, 1991, wherein you requested our opinion regarding the phrase “... from property or from property substituted” in the subject provision as it relates to the attribution of income on property transferred to a minor where a capital gain has resulted from the subsequent disposition of that property. ...
Miscellaneous severed letter
6 February 1998 Income Tax Severed Letter 9724955 F - Dividendes discrétionnaires
Le 28 janvier 1998, la Cour Suprême du Canada a entendu l'appel interjeté par le contribuable, la cause est maintenant en délibéré (référence # 25565). 2 Voir R. c. ...
Miscellaneous severed letter
7 August 1990 Income Tax Severed Letter - Technical interpretation of sections 1101 and 1204 of the Income Tax Regulations
George Thompson & Company, Limited (1927), 13 TC 83. Therein, Mr. ...
Miscellaneous severed letter
3 May 1985 Income Tax Severed Letter RRRR103 - Treatment of participation payments under U. S. Treaty
VI, XI MEMO TO FILE FINANCE & LEASING SECTION Reference: Paragraph 212(1)(d) of the Income Tax Act Canada-U. ...
Miscellaneous severed letter
7 July 1990 Income Tax Severed Letter - Application of subsection 15(2) to a hypothetical situation
Subparagraph 15(2)(a)(ii) specifically states that the employee must "... acquire a dwelling for his habitation". ...
Miscellaneous severed letter
31 May 1983 Income Tax Severed Letter RRR15 - Tax implications of setting up a pooled fund trust in the United States
B) subsection 206(1) of the Act does not apply to the pooled fund since it is none of the entities described in section 205; C) units of the pooled fund will constitute foreign property within paragraph 206(2)(h) of the Act to XXX and D) the reference in each of paragraphs 206(1)(a) and 206(1)(b) of the Act to "... the fair market value at the time of its acquisition by a taxpayer... ...
Miscellaneous severed letter
7 August 1990 Income Tax Severed Letter - Whether all property of predecessor corporations immediately before a merger become property of a new corporation by virtue of the merger
" (I think preamble in paragraph 5 was originally numbered as 5(a) and what is currently 5(a) and 5(b) are what the reviewer refers to when speaking of 5(b) and 5(c)) re: paragraph 14 "... ...
Miscellaneous severed letter
7 July 1990 Income Tax Severed Letter - Taxation of non-resident Indians
" Subsection 2(1) of the Indian Act provides that: " `Indian moneys' means all moneys collected, received or held by Her Majesty for the use and benefit of Indians or bands. ...
Miscellaneous severed letter
7 July 1991 Income Tax Severed Letter - Interpretation of subsection 110.6(8) involving the capital gains deduction in a particular situation
The matter of whether a significant part of the capital gain realized on the disposition of the common shares would be attributable to the fact dividends were not paid on the preferred shares is a question of fact that could not be determined without "... having regard to all the circumstances" [ss. 110.6(8)]. ...