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8 March 1990 Ruling 59601 F- Non-Arm's Length Transfer/Interest Deduction Unedited CRA Tags 69(1), 20(1)(c), 9(3) 19(1) File No. 5-9601   D.S. Delorey   (613) 957-3495 March 8, 1990 19(1) This is in reply to your letter of February 9, 1990. ...

16 June 1989 Ruling 57801 F- Application of Automobile Allowance to Clergymen Unedited CRA Tags 6(1)(b)(xi), 8(1)(h) 19(1) File No. 5-7801   S. Short   (613) 957-2134 June 16, 1989 Dear Sirs: Re:  Automobile Allowance as Relate to Clergymen This is in reply to your correspondence dated March 31, 1989 wherein you have queried whether subparagraph 6(1)(b)(xi) of the Income Tax Act (the "Act") will be applied to clergyman or whether relief will be granted towards this particular class of taxpayer. ...

9 October 1990 Ruling 59443 F- Swap Transactions Part of Bank's Income or Loss from International Banking Centre Unedited CRA Tags 33.1(4)(a), 33.1(1) 24(1) 5-9443   C. Robb   957-2744 Attention: 19(1) October 9, 1990 Dear Sirs: Re:  Paragraph 33.1(4)(a) of the Income Tax Act (the "Act") We are writing in response to your letters of January 19 and 23, 1990 in which you requested our views concerning whether a foreign currency swap transaction ("swap") forms part of a bank's income or loss from an international banking centre ("IBC") business. ...

28 May 1990 Ruling 59623 F- Series of Share Exchanges Unedited CRA Tags 7(1.5), 7(1.1), 85.1(1), 87, 110(1)(d.1) 24(1) File No. 5-9623   J.D. Jones   (613) 957-2104 19(1) May 28, 1990 Dear Sirs: Re:  Subsection 7(1.5) of the Income Tax Act (the "Act") This is in reply to your letter of February 16, 1990, wherein you requested a technical interpretation with respect to the application of subsection 7(1.5) of the Act in the following situation. ...

5 December 1989 Ruling 58891 F- Royalty Interests as Active Business Income Unedited CRA Tags 55(3)(b), 125 19(1) 5-8891   J. Shaw   (613) 957-8968 December 5, 1989 Dear Sirs: Re:  Request for Technical Interpretation Royalty interests and each of paragraph 55(3)(b) and section 125 of the Income Tax Act (the "Act") This is in reply to your letter of October 6, 1989, in which you requested our opinion regarding the nature of royalty interests for the purposes of paragraph 55(3)(b) of the Act and the nature of income therefrom for the purposes of the small business deduction rules in section 125 of the Act. ...

2 October 1989 Ruling 58541 F- Transfer of Retiring Allowance to an RRSP Unedited CRA Tags 60(j.1) 19(1) File No. 5-8541   D.S. Delorey   (613) 957-3495 October 2, 1989 Dear Sirs: This is in reply to your letter dated July 27, 1989 concerning the transfer of a retiring allowance to a Registered Retirement Savings Plan ("RRSP") under paragraph 60(j.l) of the Income Tax Act (the "Act"). ...

30 May 1990 Ruling 59673 F- Automobile Standby Charge Unedited CRA Tags n/a 19(1) File No. 5-9673   J.D. Jones   (613) 957-2104 May 30, 1990 19(1) Re: Automobile Standby Charge This is in reply to your letter of February 12, 1990, wherein you requested a ruling with respect to the assessment of an automobile standby charge by your employer in the following situation. ...

18 July 1990 Ruling 900403 F- Low Interest Loans by Employers to Employees Unedited CRA Tags 80.4 24(1) 900403   A. Humenuk   (613) 957-2135 Attention: 19(1) EACC9421 July 18, 1990 Dear Sirs: Re:  Low Interest Loans We are replying to your letter of April 9, 1990, concerning the- exceptions to the deemed benefit calculation under section 80.4 of the Income Tax Act. ...

20 October 1989 Ruling 58573 F- Gift By Will Unedited CRA Tags 118.1, 104(4)(a) 19(1) File No. 5-8573   J.D. Jones   (613) 957-2104 October 20, 1989 Dear Sirs: Re:  Subsection 118.1(6) and Paragraph 104(4)(a)  of the Income Tax Act (the "Act") This is in reply to your letter of August 24, 1989 wherein you requested our opinion as to the applicability of subsection 118.1(6) of the Act in relation to paragraph 104(4)(a) of the Act in the following situation. ...

15 February 1990 Ruling 59551 F- Interest Deduction- Discount on Issue of Bankers Acceptance Unedited CRA Tags 20(1)(c), 20(1)(e.1) 19(1) File No. 5-9551   S.J. Tevlin   (613) 957-2118 February 15, 1990 Dear Sirs: Re:  Paragraphs 20(1)(c) and 20(1) (e.1) of the Income Tax Act (the "Act") We are writing in response to your letter of January 18, 1990, and our several telephone conversations wherein you requested our opinion on the application of paragraphs 20(1)(c) and 20(1)(e.1) of the Act in the following situation. ...