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Barnes New Canada-United Kingdom Tax Treaty Article 17-Pensions and Annuities In your memo to us dated April 25 you asked for our comments in connection with the interpretation of the Article on pensions to be included in the new treaty with the U.K. ...

While the issue is always a question of fact it is our view that the services performed as described above by FA for CCPC-II would not be services performed in connection with the purchase or sale of goods and therefore those services would be considered to be services for the purposes of paragraph 95(2)(b) of the Act. ...

In connection with the five year repayment requirement in subparagraph 212(1)(b)(vii), it is our position that foreign currency fluctuations of the Canada dollar as against the U.S. dollar will not be taken into account in determining as at a particular date whether the Canadian borrower is under any circumstances obliged to pay are than 25% of the principal amount of the loan referred to above within five years of the date of issue. ...

McNabb seeking the Department's views regarding the tax treatment of 19(1) As discussed with you on May 16, 1989, and previously with 19(1) the issues involved in your enquiry are presently being considered by personnel of the Vancouver District Office in connection with a tax return already filed and thus we are unable to comment on the matter at this time. ...

Castendyk 957-2063 Dear Sir: We are writing to you in connection with Articles 25, 22 and 11 of the Canada-Brazil Income Tax Convention. ...

Warren 613-593-6937 Attention: XXXX April 29, 1981 Dear Sirs: This is in reply to your letter of October 29, 1980 in connection with the meaning of related. ...

Boehmer (613) 957-2120 ATTENTION Chief of Audit RE: XXXX We are writing in connection with certain advance income tax rulings that were requested on behalf of XXXX. ...

Baumeister (613) 995-0051 November 12, 1982 Dear Sirs: We have for reply your letter of October 8, 1982, in connection with policy loans under a life insurance policy. ...

Thompson 957-9227 SUBJECT: Re-Audit Communique S A-85-8 The Remission Committee has for consideration a request for a remission of tax in connection with an assessment under subsection 159(3) of tax owing by an estate. ...

Calderwood Director RE: Continuity of Reserves I refer to your memorandum of December 16 in connection with GRIER v. ...