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Tremblay (613) 957-2139 APR 22 1988 Dear Sirs: This is in reply to your letter of January 13, 1988, and further to our telephone conversation of March 22, 1988 (XXXX/Tremblay) requesting our views on the income tax implications concerning payments received by your clients in connection with the expropriation of rights or of land by XXXX. ...

You ask whether the partners will each be able to claim, in calculating their respective incomes from the partnership for its final year, reserve under paragraph 20(1)(m) of the Act in connection with the customer deposits that have been included in their respective incomes under paragraph 12(1)(a) of the Act. ...

Mason (613) 957-2109 March 18, 1988 Dear Sirs: Re: Advance Income Tax Ruling Request XXXX We are writing in connection with your advance income tax ruling request dated November 3,1987 on behalf of the above-mentioned taxpayer, and your further submission of February 26, 1988. ...

In this regard, note that pursuant to subsection 146.3(11) of the Act, if an agreement is revised and it does not comply with the requirements of subsection 146.3(2) of the Act, the fund shall be deemed, for purposes of the Act, not to be an RRIF and the annuitant will be required to include in income an amount equal to the fair market value of all property held in connection with the fund immediately before that time. ...

Jane (613) 957-2126 Dear XXXX This is in reply to your letter of September 29, 1986 regarding the proper income tax treatment of two types of expenses: 1) the payment of a real estate agent's commission and legal fees in connection with the aborted sale of the taxpayer's rental property and 2) the loss of a deposit given to a building contractor who became bankrupt. ...

You have referred to our responses to certain questions at the 1981 and 1983 Canadian Tax Foundation Conferences where it was indicated that generally the Department will not challenge the reasonableness of salaries and bonuses paid to the principal shareholders-managers of a corporation when (a) the general practice of the corporation is to distribute the profits of the company to its shareholders-managers in the form of bonuses or additional salaries; or (b) the company has adopted a policy of declaring bonuses to the shareholders to remunerate them for the profits the company has earned that are attributable to the special know-how, connections or entrepreneurial skills of the shareholders. ...

Provided our understanding of the facts is correct, in our view, a 15 per cent withholding under subsection 105(1) of the Income Tax Regulations (the "Regulations") is required in respect of travelling costs and other out of pocket expenses incurred by a non-resident in connection with services rendered in Canada. ...

1 May 1991 Income Tax Severed Letter Edmonton District Office Annual Tax Group Meeting Q.17 Price Adjustment Clauses Price adjustment clauses are commonly used in connection with shares issued in the context of section 85 rollovers and section 86 reorganizations. ...

Specifically, you requested the Department's views as to whether the field of architecture is qualified activity and whether an employer would be considered to be carrying on a business in a foreign country to which an employee was sent to perform duties in connection with a contract under which the employer provided architectural services to a construction company resident in that country. ...

Article XI(3)(d) of the Convention is as follows: The interest is beneficially owned by a seller who is a resident of the other Contracting State and is paid by a purchaser in connection with the sale on credit of any equipment, merchandise or services, except where the sale is made between persons dealing with each other not at arm's length. ...