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We apologize for the delay in responding to you, which arose because we considered it necessary to undertake consultations with the Department of Finance in connection with subparagraph 7(b) of Article 13 of the Convention. ...

Paragraphs 149.1(3)(d) and 149.1(4)(d) allow the Minister to revoke the registration of a public or a private foundation, if the foundation "incurred debts, other than debts for current operating expenses, debts incurred in connection with the purchase and sale of investments and debts incurred in the course of administering charitable activities. ...

In general, where a limited partnership engages another party to perform services in connection with a business carried on by the partnership and the other party does not deal at arm's length with the general partner of the partnership or some or all of its limited partners, the fees charged for such services would not be rendered non-deductible under the Income Tax Act, solely because of the non-arm's length relationship. ...

7 July 1990 Income Tax Severed Letter- Deductibility of expenses paid to a school as medical expenses Unedited CRA Tags 118.2(2)(e) Subject: Deductibility of Medical Expenses in respect of XXX We are enclosing, for your information, a copy of our correspondence with XXX who has asked us to provide a ruling or opinion with respect to the deductibility of amounts paid in connection with XXX. ...

7 August 1990 Income Tax Severed Letter- Definition of a specified investment business Unedited CRA Tags 125(7)(e) Subject: XXX This is in reply to your letter of July 6, 1990, wherein you requested our views with respect to whether XXX Our Comments XXX In this connection, we note that "active business carried on by a corporation" means any business carried on by the corporation other than a specified investment business or a personal services business. ...

We apologize for the delay in responding to your inquiry which arose because we considered it necessary to undertake consultations with the Department of Finance in connection with this matter. ...

In your situation, Company A, which is controlled by XXX brothers, sold its XXX business but retained a property that was initially acquired subsequent to 1971 for expansion purposes in connection with the XXX operation As the company now has a large amount of pre-1972 capital surplus on hand, it is proposed that a new company (Company B) will be incorporated which would also be controlled by the brothers. ...

In other cases, consideration of all verbal and written representations made in connection with the particular offering would be necessary in order to determine the applicability of subparagraph 237.1(1)(a)(ii). ...

Prosia, he indicated that to the best of his knowledge, the above noted penalty provisions are not given consideration in connection with the collection procedures instituted as a result of the application of 159(3). ...

29 April 1981 Income Tax Severed Letter RRRR41- Meaning of “related” Unedited CRA Tags 251(2), 251(6), 252, 94(1)(b)(i)(A) Dear Sirs: This is in reply to your letter of October 29, 1980 in connection with the meaning of related. ...