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18 December 1990 Ruling 902343 F- Maintenance and Support Payments Subsequent to Death of Former Husband Unedited CRA Tags 56(1)(b), 56(1)(c), 60(b), 60(c) 24(1) 902343   M. Eisner   (613) 957-2138 19(1) December 18, 1990 Dear Sirs: This is in reply to your letter of August 22, 1990 concerning whether certain amounts for maintenance and support received by a taxpayer subsequent to the death of her former husband must be included in income. ...

14 March 1990 Ruling 59421 F- Definition of a "Qualified Small Business Corporation Share" Unedited CRA Tags 110.6(1) qualified small business corporation share, 125(7) Canadian-controlled private corporation, 248(1) small business corporation, 251(2) 19(1) File No. 5-9421   S. Shinerock   (613) 957-2108 March 14, 1990 Dear Sirs: Re:  Definition of a Small Business  Corporation Share ("QSBCS") in Subsection 110.6(1) of the Income Tax Act (the "Act") We refer to your letter of January 12, 1990 in which you requested a technical interpretation as to whether a share of Aco, a Canadian-controlled private corporation ("CCPC"), within the meaning assigned by paragraph 125(7)(b) of the Act, qualifies as a QSBCS in the following hypothetical situation. ...

11 June 1990 Ruling 33011 F- Advance Income Tax Ruling Unedited CRA Tags n/a 24(1) File No. 3-3011   P. Diguer   (613) 957-2123 19(1) June 11, 1990 Dear Sirs: Re:  Advance Income Tax Ruling  24(1) This is in response to your letter of May 10, 1990, wherein you advised us that you wish to withdraw your request for an advance income tax ruling as outlined in your letter to us dated March 6, 1990. ...

5 April 1990 Ruling 59581 F- Capital Gains Deduction- Qualified Small Business Corporation Share Unedited CRA Tags 110.6(1) qualified small business corporation share, 248(1) small business corporation, 248(1) active business 19(1) File No. 5-9581   J.E. Harms   (613) 957-2109 April 5, 1990 Dear Sirs: Re:  Qualified small business corporation share Small business corporation Assets used in an active business Request for a technical interpretation This is in reply to your letter of February 9, 1990 in which you requested our opinion with respect to the meaning of the phrase "assets that were used in an active business"  in the definition of small business corporation" in subsection 248(1) of the Income Tax Act (the "Act"). ...

Resident with respect to Software Purchases by a Resident of Canada Unedited CRA Tags n/a 19(1) File No. 5-8381   K.B. Harding   (613) 957-2129 August 29, 1989 Dear Sirs: This is in reply to your memorandum of July 12, 1989 wherein you requested information concerning the tax treatment of payments made to a U.S. resident with respect to software purchases by a resident of Canada. ...

6 July 1989 Ruling 57793 F- Finders Fees Paid to a Non-Resident Unedited CRA Tags 212(1)(d)(iii) 19(1) File No. 5-7793   R.C. O'Byrne   957-2126 July 6, 1989 Dear Sirs: Re:  Subparagraph 212(1)(d)(iii) of the Income Tax Act (the "Act") This is in reply to your letter of March 20, 1989 in which you asked whether Part XIII tax should be withheld in the following situation: 24(1) As the situation you have outlined relates to a particular taxpayer we are unable to comment specifically thereon as technical interpretations are only provided in respect of hypothetical situations.  ...

20 November 1989 Ruling 58681 F- Tax Shelter- Meaning of Prescribed Benefits Unedited CRA Tags 231(6)(b)(ii), 237.1(1), 146(5) 19(1) File No. 5-8681   M. Eisner   (613) 957-2138 November 20, 1989 Dear Sirs: This is in reply to your letter of September 15, 1989 concerning whether certain benefits are "prescribed benefits" described in subparagraph 231(6)(b)(ii) of the Income Tax Regulations for the purposes of the definition of "tax shelter" in subsection 237.1(1) of the Income Tax Act. ...

15 February 1990 Ruling 58851 F- Non-Arm's Length Sale of Shares Unedited CRA Tags 84.1, 251(1)(b), 251(1)(a) 19(1) File No. 5-8851   M. Vallée   (613) 957-2093 February 15, 1990 Dear Sir: Re:  Technical Interpretation- Section 84.1 of the Income Tax Act (the "Act") This is in reply to your letter dated October 4, 1989, whereby you requested a technical interpretation regarding the application of section 84.1 of the Act in the following hypothetical situation. 1.      ... B are brothers who own all the shares of Opco, which carries on an active business. 2.      ...

In your opinion, subsection 80(1) of the Act should not be applicable for the following reasons: 1.      ... Thus, a conversion would not be considered to "settle" or "extinguish" the debt. 2.      ... Conversion is not included in the examples of settlement and although it changes the liability, it does not terminate it. 3.      ...

15 January 1990 Ruling 74113- Assurance-vie universelle co-participation Unedited CRA Tags 6(1)(a), 15(1) 19(1) File No. 7-4113   V. ... VOTRE QUESTION 1.     Vous désirez savoir si 1'actionnaire cadre pourrait être imposable sur un certain montant advenant le cas ou la compagnie choisisse l'option de payer le dixième de la valeur au comptant de la dixième année de la police. ... Cependant nous vous offrons les commentaires généraux suivants qui pourraient ne pas s'appliquer à votre situation particulière. 3.      ...