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If we may be of assistance in connection with your review of the foregoing problem, please advise. ...

Oulton (613) 995-1787 XXXX Dear Sirs: Re: Foreign Affiliates This is in reply to your letter of January 26, 1981 in connection with the above. ...

Jane (613) 957-2126 XXXX April 9, 1987 INDEXED Re: Article XVIII Canada-U.S. income Tax Convention This is in reply to your letter of October 1, 1986 in connection with the above noted matter. ...

In this connection, you ask if it makes any difference whether the exchanged shares were authorized shortly before and in anticipation of the exchange by the filing of articles of amendment or if they had been authorized before the exchange was contemplated. ...

Accordingly, the independent dealer in receipt of the benefit would include the amount of the benefit (i.e. equal to the rent amount paid by the operating company) in his income. 5) Because of concerns in connection with U.S. estate tax, the Canadian individual would incorporate a new Canadian company (Newco) wholly owned by him, to acquire the recreational property. ...

., payments for motion pictures to be shown in the cinema would not be exempt), motion pictures that are on videotape and are for private (home) use would fall within the exemption on the basis that "works on videotape" is more specific. 21(1)(A) The wording in the brackets in paragraph 3 of Article XII of the Convention may create some ambiguity since it was not clear whether the words "for use in connection with television" applied only to the last term " other means of reproduction" or whether it applied to the other antecedents in the backers. ...

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. ...