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2 June 1989 Ruling 57633 F- Source of Income- Non-Competiton Agreement Unedited CRA Tags 126(1), 42   19(1) File No. 5-7633   S. ... Your client will receive consideration for entering into such agreement. 3.      ... It is, however, our view that, provided 1)     the capital gain on the sale of the shares of the U.S. subsidiary is form a U.S. source, 2)     the non-competition agreement will be executed in the U.S., and 3)     the application of the non-competition agreement is restricted to U.S. territories, the consideration to be received with respect to the non-competition agreement would likely be considered to be from a U.S. source for purposes of subsection 126(1) of the Act. ...

5 December 1990 Ruling 901703A F- Research Project Unedited CRA Tags n/a 19(1) 901703   J.D. Brooks   (613) 957-2097 December 5, 1990 Dear:  19(1)  Re:  Research Project  24(1) Thank you for your letter of August 21, 1990. ...

28 August 1989 Ruling 32483 F- Withdrawal of Ruling Unedited CRA Tags n/a 19(1) File No. 3-2483   K. Astaphan   (613) 957-2119 August 28, 1989 Dear Sirs: Re:  24(1) This will confirm receipt of your letter of August 15, 1989, wherein you advised that you wished to withdraw the above-noted request for advance income tax ruling which was outlined in your letter of May 26, 1989 and amended by your letter of July 9, 1989. ...

18 December 1989 Ruling 32573 F- Acquisition of Shares Unedited CRA Tags n/a 19(1) 3-2573   Peter Lee   (613) 957-2745 December 18, 1989 Dear Sir: Re:  24(1) Acquisition of Shares 24(1) Our inability to rule should not be construed as either a negative or a positive ruling but solely as an inability to reach any conclusion on the available facts. 24(1) We are closing our file on this request.  ...

18 December 1989 Ruling 59113 F- Ten-Year Debenture Financing Unedited CRA Tags n/a 19(1) 5-9113   C. Robb   (613) 957-2744 December 18, 1989 Dear Sirs: We are writing in response to your letter of November 15, 1989 in which you have requested our views concerning a proposed Ten Year Debenture Financing. ...

11 January 1990 Ruling 1931 F- Advance Income Tax Ruling 3-2730 (January 11, 1990) Unedited CRA Tags n/a 19(1) 1-931   C. Robb   (613) 957-2744 Dear Sirs: Re:  Advance Income Tax Ruling 3-2730 dated January 11, 1990 24(1) This letter is to confirm that the date by which the Second Loan is to be repaid, as described in fact 14 of the above ruling, is changed to December 31, 1990 from July 31, 1990. ...

12 December 1989 Ruling 32743 F- Advance Income Tax Ruling Request Unedited CRA Tags n/a 19(1) 3-2743   S. Leung   (613) 957-2116 December 12, 1989 Dear Sirs: Re:  19(1) Advance Income Tax Ruling Request We are writing to acknowledge your letter of November 30, 1989 in which you advised that you wish to withdraw the above-noted request for an advance income tax ruling which was outlined in your letter of September 28, 1989.  ...

22 January 1990 Ruling 32551 F- Request for Income Tax Ruling Unedited CRA Tags n/a 19(1) File No. 3-2551   A.A. Cameron   (613) 957-2115 January 22, 1990 Dear Sirs: Re:  24(1) This will confirm our telephone conversation of January 16, 1990 wherein you advised that you wished to withdraw the request for an advance income tax ruling concerning the above-noted corporation which was outlined in your letter of July 5, 1989. ...

18 June 1990 Ruling 900371 F- Contractual Estate Freeze Unedited CRA Tags 54 disposition 19(1) File No. 900371   P.W. Osborn   (613) 957-2120 June 18, 1990 Dear sirs: Re:  Contractual Estate Freeze- Your File 19(1) We are writing in reply to your letter of April 11, 1990 in which you requested our opinion of the application of section 54 of the Income Tax Act to a pending series of transactions and events. ...

29 January 1990 Ruling 32401 F- Request for Advance Income Tax Ruling Unedited CRA Tags n/a 19(1) File No. 3-2401   K. Astaphan   (613) 957-2119 January 29, 1990 Dear Sirs: Re:  Request for Advance Income Tax Rulings on behalf of  24(1) This will confirm that on January 11, 1990 you advised us that you wish to withdraw the above-noted request for advance income tax rulings outlined in your letter of March 28, 1989, as amended subsequently. ...