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25 August 1989 Income Tax Severed Letter 5-8483- Deferred annuities issued in connection with segregated funds Unedited CRA Tags 146(1)(i.1), 146(1)(g)(iii) Dear Sirs: This is in reply to your letter of August 10, 1989 concerning annuities issued by XXX in connection with its segregated funds. ...

7 September 1990 Income Tax Severed Letter- Review of draft form “Designation of Retiring Allowances as Qualifying Transfers in Connection with a Past Service Event in Respect of a Defined Benefit Provision of a Registered Pension Plan” Unedited CRA Tags none Subject: DRAFT FORM "Designation of Retiring Allowances as Qualifying Transfers in Connection with a Past Service Event in Respect of a Defined Benefit Provision of a Registered Pension Plan" This is in reply to your round trip memorandum of August 24, 1990 concerning the review of the above-noted form. ...

7 August 1990 Income Tax Severed Letter- Whether a utility service connection cost incurred should, in terms of fiscal policy, be deductible even though the payments was made to a person other than the person who supplied the service Unedited CRA Tags 20(1)(ee) Subject: Paragraph 20(1)(ee) of the Income Tax Act (the "Act") Further to our recent telephone conversation with Don Joy, we request your comments as to whether a utility service connection cost incurred in the circumstances described below should, in terms of fiscal policy, be deductible even though the payments was made to a person other than the person who supplied the service. ...

30 August 1990 Income Tax Severed Letter ACC9225- Deductibility of Utility Service Connection Cost Current Amendments and Head Office Regulations Division Rulings Directorate B. ... Fontaine Acting Director 957-2095 900443 Paragraph 20(1) (ee) of the Income Tax Act (the "Act") Further to our recent telephone conversation with Don Joy, we request your comments as to whether a utility service connection cost incurred in the circumstances described below should, in terms of fiscal policy, be deductible even though the payment was made to a person other than the person who supplied the service. ...

25 August 1989 Income Tax Severed Letter ACC58483- Annuities Issued in Connection to Segregated Funds 5-8483 19(1) M. Shea-DesRosiers (613) 957-8953 August 25, 1989 Dear Sirs: This is in reply to your letter of August 10, 1989 concerning annuities issued by 24(10 in connection with its segregated funds. ...

7 November 1990 Income Tax Severed Letter- Deductibility of Costs Incurred in Connection with a Takeover Bid Unedited CRA Tags none Subject: Deductibility of costs incurred in connection with a takeover bid On November 2, 1990, Mr. ...

11 May 1992 Income Tax Severed Letter 9210710- Letter of Credit in Connection with a RCA CALU ANNUAL MEETING May 11, 1992Question 9 RETIREMENT COMPENSATION ARRANGEMENTSDRAFT/EBAUCHE Supplementary retirement income benefits may be secured for employees with a bank letter of credit. ...

2 May 1991 Income Tax Severed Letter 7-903080- Payments in Connection with the Financing of a Company's Operation May 2, 1991 Belleville District Office Rulings Directorate J.E. ... M.N.R., [1949] S.C.R. 287 [49 DTC 514], where it was held that commission payments were not allowable as deductible expenses since they were incurred in connection with the financing of the business and were not related to the income earning process. ... Broadhurst's summary in the 1989 Conference Report ("Income Tax Treatment of Foreign Exchange Forward Contracts, Swaps and Other Hedging Transactions" p. 26:13): 000321 The case law in Canada has consistently regarded payments made in connection with the financing of a company's operation as being on capital account unless the taxpayer is engaged in a money-lending business. ...

28 December 1989 Income Tax Severed Letter 5-8491- Tax treatment of several arrangements which charitable organizations are either using or contemplating using in connection with their fund-raising activities Unedited CRA Tags 12.2(3), 56(1)(d.1), Reg. 304(1)(c) Dear Sirs: This is in reply to your letter of August 10, 1989, requesting our views on the tax treatment of several arrangements which charitable organizations are either using or contemplating using in connection with their fund raising activities. ...

7 August 1990 Income Tax Severed Letter- Technical interpretation in connection with a hypothetical situation in which arm's length partners agree to allocate partnership income and loss Unedited CRA Tags 96(1)(d), 96(1)(g), 103 Dear Sirs: Re: Request for Technical Interpretation Paragraphs 96(1)(d) and (g) and Section 103 of the Income Tax Act (the "Act") We are writing to reply to your letter dated March 19, 1990 wherein you requested a technical interpretation in connection with a hypothetical situation in which arm's length partners agree to allocate partnership income and loss. ...