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Ruling

27 March 1990 Ruling 59773 F - Claim for Child Care Expenses

27 March 1990 Ruling 59773 F- Claim for Child Care Expenses Unedited CRA Tags n/a 19(1) File No. 5-9773   J.D. Jones   957-2104 March 27, 1990 Dear Sirs: Re: Claim for Child Care Expenses This is in reply to your letter of March 5, 1990, wherein you requested our opinion concerning the issuance of receipts on the basis that such receipts are "child care expenses" for income tax purposes. ...
Ruling

5 April 1990 Ruling 59803 F - Deferred Salary Leave Plan

5 April 1990 Ruling 59803 F- Deferred Salary Leave Plan Unedited CRA Tags 6801 19(1) File No. 5-9803   D. Duff   (613) 957-3498 April 5, 1990 Dear Sirs: Your letter of March 8, 1990 to the Halifax District Taxation Office of Revenue Canada, Taxation, regarding a Deferred Salary Leave Plan, has been forwarded to this office for reply. ...
Ruling

18 January 1990 Ruling 59243 F - Shareholder Debt - Trade Accounts Receivable

18 January 1990 Ruling 59243 F- Shareholder Debt- Trade Accounts Receivable Unedited CRA Tags 15(2)(b) 19(1) File No. 5-9243   J.D. Jones   (613) 957-2104 January 18, 1990 Dear Sirs: Re:  Paragraph 15(2)(b) of the Income Tax Act (the "Act") This is in reply to your letter of December 12, 1989, wherein you requested the Department confirm a previous view expressed with respect to the application of paragraph 15(2)(b) of the Act to trade accounts receivable. ...
Ruling

24 October 1990 Ruling 902873 F - Political Contributions

24 October 1990 Ruling 902873 F- Political Contributions Unedited CRA Tags 127(3) 24(1) 902873   L. Holloway   (613) 957-2104 19(1) October 24, 1990 Dear Sirs: Re:  Political Contributions under Section 127(3) of the Income Tax Act This is in response to your letters dated October 16, 1990 and October 18, 1990 requesting copies of a 1989 Advance Tax Ruling regarding the tax credit available for political contributions under subsection 127(3) of the Income Tax Act. ...
Ruling

1 October 1990 Ruling 59843 F - Intercorporate Dividends - Meaning of "Reduction in the Portion of the Capital Gain"

1 October 1990 Ruling 59843 F- Intercorporate Dividends- Meaning of "Reduction in the Portion of the Capital Gain" Unedited CRA Tags 55(2), 55(5)(f), 112(3) 24(1) 5-9843   D. Yuen   (613) 957-2111 19(1) October 1, 1990 Dear Sirs: Re:  Subsection 55(2) of the Income Tax Act (the "Act") We are responding to your letter of March 21, 1990 wherein you requested our comments on whether the phrase "reduction in the portion of the capital gain" as found in subsection 55(2) of the Act (the "phrase") includes the creation of, or increase in, a capital loss. ...
Ruling

21 December 1989 Ruling 57001 F - Foreign Affiliate - Change of Control

21 December 1989 Ruling 57001 F- Foreign Affiliate- Change of Control Unedited CRA Tags 95(1) taxation year, 249(4) 19(1) 5-7001   D.Y. Dalphy   (613) 957-2117 December 21, 1989 Dear Sirs: Re:  Foreign Affiliate- Change of Control This is in reply to your letter of November 7, 1988 regarding foreign affiliates an subsection 249(4) of Income Tax Act (the Act), which is applicable with respect to acquisitions of control occurring after January 5, 1987 (other than certain "grandfathered" acquisitions). ...
Ruling

23 March 1990 Ruling 59741 F - Contributions to RPP by Teacher

23 March 1990 Ruling 59741 F- Contributions to RPP by Teacher Unedited CRA Tags 8(1)(m)(ii), 8(7), 8(1)(m.1) 19(1) File No. 5-9741   A.B. Adler   (613) 957-8962 March 23, 1990 Dear Sirs: This is in reply to your letter dated March 2, 1990 in which you requested our views with respect to the application of subparagraph 8(1)(m)(ii) and subsection 8(7) of the Income Tax Act ("Act"). ...
Ruling

21 August 1990 Ruling 901413 F - Butterfly Transactions

21 August 1990 Ruling 901413 F- Butterfly Transactions Unedited CRA Tags 55(3)(b) 24(1) 901413   P. Diguer   (613) 957-2123 Attention: 19(1) EACC9238 August 21, 1990 Dear Sirs: Re: Advance Income Tax Ruling 24(1) This is further to our telephone conversation of July 17 and August 2, 1990 (19(1) Diguer) concerning your request for an advance income tax ruling, dated June 20, 1990, submitted on behalf of the above-noted taxpayers. ...
Ruling

19 October 1989 Ruling 58581 F - Flexible Benefits Plan

19 October 1989 Ruling 58581 F- Flexible Benefits Plan Unedited CRA Tags n/a 19(1) File No. 5-8581   J.D. Jones   (613) 957-2104 October 19, 1989 Dear Sirs: Re:  Flexible Benefits Plan This is in reply to your letter of August 24, 1989, wherein you requested our opinion on the implementation of a proposed flexible benefits plan of one of your clients. ...
Ruling

30 August 1990 Ruling 900873 F - U.S. Estate Taxes

Estate Taxes Unedited CRA Tags 15(1) 24(1) 900873   G. Arsenault   (613) 957-2126 Attention: 19(1) EACC9244 August 30, 1990 Dear Sirs: Re:  US Estate Taxes This is in reply to you letter dated May 7, 1990. ...

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