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Ruling

2 February 1990 Ruling 32703 F - Advance Income Tax Ruling Request

2 February 1990 Ruling 32703 F- Advance Income Tax Ruling Request Unedited CRA Tags n/a 19(1) File No. 3-2703   M. Eisner   (613) 957-2138 February 2, 1990 Re: 24(1) Advance Income Tax Ruling Request In your letter of January 2, 1990, you advised us that certain information, which we require in order to proceed with our consideration of your advance income tax ruling request, will not be available until June, 1990.  ...
Ruling

21 June 1990 Ruling 900753 F - Inter-vivos Trust as Beneficiary of Term Life Insurance Policy

21 June 1990 Ruling 900753 F- Inter-vivos Trust as Beneficiary of Term Life Insurance Policy Unedited CRA Tags n/a 24(1) File No. 900753   D. Duff   (613) 957-3498 Attention: 19(1) June 21, 1990 Dear Sirs: This is in reply to your letter of May 8, 1990 regarding the naming of an inter vivos trust as the beneficiary of a term life insurance policy. ...
Ruling

4 October 1990 Ruling 902581 F - Meaning of "Foreign Affiliate"

4 October 1990 Ruling 902581 F- Meaning of "Foreign Affiliate" Unedited CRA Tags 95(1) foreign affiliate, 248 24(1) 902581   O. Laurikainen   (613) 957-2129 Attention  19(1) October 4, 1990 Dear Sirs: Re:  Meaning of "Foreign Affiliate" This is in response to your letter of September 21, 1990. ...
Ruling

29 November 1990 Ruling 902713 F - 10% Withholding Tax on Films

29 November 1990 Ruling 902713 F- 10% Withholding Tax on Films Unedited CRA Tags n/a 24(1) 902713   G. Middleton   (613) 957-2127 19(1) November 29, 1990 Dear Sirs: Re:  10% Withholding Tax on Films This is in reply to your letter of September 20, 1990 concerning the 10% Canadian withholding tax on royalties paid to the   24(1) You questioned whether there is any provision under the Canadian Income Tax Act which provides for an exemption from such tax. ...
Ruling

8 September 1989 Ruling 58353 F - Farming Operations

8 September 1989 Ruling 58353 F- Farming Operations Unedited CRA Tags 31, 110.6(1) qualified farm property 19(1) File No. 5-8353   M. Eisner   (613) 957-2138 September 8, 1989 Dear Sirs: This is in reply to your letter of July 6, 1989 concerning whether farm land, which is used in a farming operation where the deductibility of losses is restricted under section 31, can be regarded as being used in a "farming business" for the purposes of the definition of qualified farm property in subsection 110.6(1). ...
Ruling

2 November 1989 Ruling 58633 F - Partnerships

2 November 1989 Ruling 58633 F- Partnerships Unedited CRA Tags 54.2, 96 19(1) File No. 5-8633   R.B. Day   (613) 957-2136 November 2, 1989 19(1) We are writing in reply to your letter of August 30, 1989, wherein you requested our views as to whether or not a partnership would be considered a person for the purposes of section 54.2 of the Income Tax Act. ...
Ruling

15 November 1989 Ruling AC4131U3 F - Extension of Period of Detachment under Canada-U.S. Social Security Agreement

Social Security Agreement Unedited CRA Tags n/a 19(1) HBW 4131-U3   Al Watson   (613) 957-2072 November 15, 1989 Dear 19(1) Re: 19(1) This is further to your letter of September 26, 1989 concerning the granting of an extension of the sixty month period of detachment under Article V(2)(a) of the Agreement on Social Security between Canada and the United States of America (the "Agreement"). ...
Ruling

23 January 1990 Ruling HBW40003 F - Confidentiality of Information

Senécal   (613) 957-2074   HBW 4000-3 January 23, 1990 Dear Sir: This is in reply to your further letter of January 8, 1990, concerning 19(1) and her liability to pay Canadian income taxes.  ...
Ruling

10 November 1989 Ruling 58953 F - Deemed Disposition by Trust

10 November 1989 Ruling 58953 F- Deemed Disposition by Trust Unedited CRA Tags 104(4) 19(1) File No. 5-8953   A.B. Adler   (613) 957-8962 November 10, 1989 Dear Sirs: This is in reply to your letter dated October 24, 1989, and is further to ours of October 16, 1989, regarding the application of subsection 104(4) of the Income Act ("Act") to your example. ...
Ruling

14 December 1989 Ruling 59111 F - Farming Income

14 December 1989 Ruling 59111 F- Farming Income Unedited CRA Tags n/a 19(1) 5-9111   A.W. Larochelle   (613) 957-2140 December 14, 1989 Dear Sirs: Re:  Farming Income This is in reply to your letter of November 9, 1989, in which you ask if an individual who works on a family farm and receives employment income could consider such income as farming income.  ...

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