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27 June 1990 Ruling 900763 F- Application of Sections 79 and 80 Unedited CRA Tags 79, 80   June 27, 1990 OTTAWA DISTRICT OFFICE Specialty Rulings   Directorate K. ... Further to a conversation on June 21, 1990 (Machado/Yuen), this memorandum is to confirm that we will be closing our file on this matter. for Director Reorganizations and Non-Resident DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental  Affairs Branch Issue Sheet   D. Yuen   900763 Reason for File Closure The Ottawa District Office requested our comments on whether section 79 or 80 apply in a certain situation.  ...

11 December 1989 Ruling 58943 F- Charitable Organizations Unedited CRA Tags n/a 19(1) 5-8943   R.B. Day   957-2136 December 11, 1989 Dear: 19(1) We are writing in reply to your letter of October 17 and November 15, 1989, wherein you asked the following questions regarding 24(1) Our Comments 24(1) Under the disbursement quota provisions in the Income Tax Act, charitable organizations are required to disburse 80% of donations in respect of which the organization issued receipts in the immediately preceding taxation year. In determining this amount, the following gifts are excluded even though proper receipts were issued: a)     capital gifts received by bequest or inheritance; b)     gifts subject to a trust or direction to the effect that the property in question, or substituted property, be held by the charitable organization for at least ten years; and c)     gifts received from other registered charities.  ...

28 November 1989 Ruling 58321 F- Grazing Leases and Permits Unedited CRA Tags n/a CALGARY DISTRICT OFFICE HEAD OFFICE   Services, Public Utilities Attention:  G.C. ... Larochelle   (613) 957-2140   File No. 5-8321 Subject:  Grazing Leases and Permits Further to our memorandum of January 15, 1987 (copy enclosed) we have recently 23 21(1)(b) 23 21(1)(b) for Director Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

The facts related to your enquiry as described in your letters are as follows: 1.      ... Without restricting the generality of the objects as outlined in point 6, the Commission may: (a)     carry out programs to assist producers of, processors of, and dealers in cattle in achieving proper methods of production, processing, grading and marketing of cattle; (b)     carry out studies and research with respect to the production, processing, grading and marketing of cattle and consumer needs and demands as they relate to the cattle industry; (c)     carry out promotional activities in respect of production, processing, grading and marketing of cattle; (d)     advise governments on matters concerning the cattle industry; (e)     support and cooperate with other organizations which have objectives similar to those of the Commission; and (f)     establish quality standards. 8.      ... The service charge is used to fund the Commission's operations and objects. 10.      ...

Thompson   957-2099   EACC9291 Attention: 19(1) August 20, 1990 Dear Sirs: Re: Ruling for  24(1) This is in reply to your letter of July 16 addressed to our Finance Division concerning the invoice in respect of the ruling for  24(1).  ...

28 February 1990 Ruling 90M02401 F- Remission of Taxes Unedited CRA Tags n/a   February 28, 1990 HAMILTON DISTRICT OFFICE HEAD OFFICE   Technical Review Section   Publications Division Attention:  Mr. ... Lee Mary Evans Director- Taxation (613) 957-9229   File No. 90M02401 Subject: 19(1) We refer to your memorandum of January 31, 1990 recommending a remission of taxes for the above-noted taxpayer. ... To assist the Remission Committee's consideration of this matter under the guidelines in TOM 2263.22, we request your comments on the following: 1.      ...

Personal-use Property to Corporation Unedited CRA Tags 15(1), 85(1) 19(1) File No. 5-8703   M.F. Symes   (613) 957-2110 November 6, 1989 Dear Sirs: Re:  Transfer of U.S. ... An individual, X, owns personal use property in the United States. 2.      ...

7 June 1990 Ruling 74573 F- Determination of Residency Status Unedited CRA Tags 126(1), 248(1) employment, 250(1)(c)   June 7, 1990 Non-Resident Taxation Division Specialty Rulings Cheryl Charette Directorate   O. Laurikainen   957-2125   File No. 7-4573 SUBJECT: Determination of Residency Status This is in response to your memorandum to us dated December 6, 1989 wherein you have enquired whether a Canadian government employee who is on secondment to the Belgian operations of not by its statutes give the 24(1)  a Canadian crown corporation which does not by its statutes give the status/of "servant" to its employees, would nevertheless be deemed resident in Canada pursuant to paragraph 250(1)(c) of the Income Tax Act (the "Act"). ...

In your letter you requested that we provide an opinion with respect to the following questions: 1.      ... 3.     If an ownership interest in necessary, what degree of ownership is acceptable? ... Our Comments We offer the following opinions related to the above questions. 1.      ...

Our understanding of the situation set out in your letter is as follows: 1.     A taxpayer corporation (A), operated a plant prior to 1974. 2.     Subsequent to 1974, A transferred the plant to a subsidiary corporation (B). 3.     A then amalgamated with another corporation (C), to form  AC. 4.     AC then amalgamated with B to form corporation ACB. ...