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Miscellaneous severed letter

7 October 1990 Income Tax Severed Letter - Assignment of Loan to Circumvent Application of Act and Garr

The Memorandum to you from Calgary District Office dated March 22, 1990 that you forwarded to us in connection with this matter makes reference to "novation". ...
Miscellaneous severed letter

7 October 1991 Income Tax Severed Letter - Qualified Farm Property

We also acknowledge our telephone conversations in connection herewith XXX Woolley). ...
Miscellaneous severed letter

7 February 1991 Income Tax Severed Letter - Canada-Germany Income Tax Agreement - Interest in Partnership

We apologize for the delay in responding to you, which delay arose because we considered it necessary to undertake consultations with the Department of Finance in connection with this matter. ...
Miscellaneous severed letter

7 November 1990 Income Tax Severed Letter - U.S. Internal Revenue Code Re Treatment of Certain Interests in Corporations as Stock or Indebtedness

In our opinion, the interest paid by USCo to Canco on the loan made by Canco to USCo would be considered to be interest and taxable as such under the Income Tax Act and Canco would not be entitled to a deduction under section 113 of the Act in connection therewith, irrespectively of whether such interest is recharacterized and deemed to be a dividend by and for the purposes of the United States Internal Revenue Code. ...
Miscellaneous severed letter

7 June 1991 Income Tax Severed Letter - Canada-Korea Income Tax Convention

Canada has no responsibility and authority in connection therewith. Accordingly, we recommend that you communicate directly with the taxation authorities of the Republic of Korea concerning taxation by that country. ...
Miscellaneous severed letter

7 June 1991 Income Tax Severed Letter - Pollution Control Property - Classifications for Capital Cost Allowance

The equipment must have more than a casual relationship with the prevention, reduction, or elimination of pollution, but rather, a direct connection must exist between the two, ie. the equipment and the pollution which is being caused by the taxpayers operations. ...
Miscellaneous severed letter

29 March 1990 Income Tax Severed Letter AC59429 - Tax Shelter Reporting

As described in paragraph 3 of Information Circular IC 89-4 [Information Circular 89-4], paragraph 237.1(1)(b) of the Act defines a tax shelter as any property of which it is expected, based on statements or representations made or proposed to be make in connection with the property, that the aggregate of losses or other amounts, calculated in any of the relevant years, which a purchaser will be entitled to deduct in taxation years ending within four years of the date of acquisition of the property will exceed the cost of the interest in the property (less prescribed benefits) to the purchaser. ...
Miscellaneous severed letter

7 February 1991 Income Tax Severed Letter - Non-resident Withholding Tax in respect of Royalties

In connection with this business, the BD Partnership pays royalties to Corporation X and Corporation X, in turn, pays royalties (in equal amounts) to Corporations A and C. ...
Miscellaneous severed letter

7 October 1990 Income Tax Severed Letter - Settlement of Loan Without Payment

Co. in connection with any business carried on by it in Canada. 3. The loan is not repaid by the end of Year 2 with the result that subsection 15(2) and paragraph 214(3)(a) apply to deem the amount of the loan to be a dividend paid by Canco to U.K. ...
Miscellaneous severed letter

7 October 1990 Income Tax Severed Letter - Non-profit Organizations

7 October 1990 Income Tax Severed Letter- Non-profit Organizations Unedited CRA Tags 149(5) XXX Re: Non-Profit Organizations This is in reply to your letter of October 15, 1990 and further to our telephone conversations of October 17 and 19, 1990 requesting a written interpretation of certain facts in connection with a non-profit sporting or recreational organization (the "NPO") of which you are a member. ...

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