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24 August 1989 Income Tax Severed Letter AC57674 - Computation of Foreign Accrual Property Income (FAPI)

We concur with your interpretation and will bring this matter to the attention of our Current Amendments Division for their consideration. ...

22 August 1990 Income Tax Severed Letter ACC9285 - Gifts Qualifying as Charitable Donations

You seek our views as to 24(1).As advanced income tax rulings are only given in respect of proposed transactions subject to the guidelines in Information Circular IC 70-6R (a copy is enclosed for your information), we can only provide you with some general comments. 24(1) OUR COMMENTS A gift is a voluntary and gratuitous transfer of real or personal property without consideration. ...

10 November 1989 Income Tax Severed Letter AC57940 - Foreign Affiliates

You presented the following situations to us for our consideration: Corporation A, resident in Canada, owns all the shares of Corporation X, a foreign affiliate. ...

25 September 1990 Income Tax Severed Letter AC74724 - Privileges and Immunities of International Organizations

We do not have sufficient information concerning the staff retirement funds or the circumstances under consideration by you in connection therewith to comment definitively as to the proper tax treatment thereof. ...

27 April 1990 Income Tax Severed Letter AC58514 - Reimbursement of Automobile Expenses

Although an allowance based on the 31 cents/25 cents per kilometre rate specified in draft Regulation 7305 may be considered reasonable in many situations, it is our view that the actual costs incurred by an employee should be taken into consideration in determining what would be a reasonable rate for the allowance. ...

15 May 1990 Income Tax Severed Letter 5-9342 - []

The consideration received by the parent might include a preferred share retractable at the option of the parent for an amount equal to the fair market value ("FMV") of the Opco shares transferred. ...

25 January 1990 Income Tax Severed Letter AC585755 - Non-resident Withholding Tax on Interest Payment

Whether or not a particular legal defeasance is a legal defeasance which effects novation can only be determined following consideration of all of the terms and conditions pertaining to the particular defeasance. ...

21 August 1989 Income Tax Severed Letter ACC8377 - Capital Dividend Account

Specifically, you have referred the following example for our consideration: A corporation, whose fiscal year end is September 30, has been carrying on business since before January 1, 1972. ...

10 September 1990 Income Tax Severed Letter AC59070 - Wage Loss Replacement Plans

Briefly, the proposal under consideration concerns the addition of a rider to a group accident and sickness policy which is part of a wage loss replacement plan pursuant to an employer-employee agreement. ...

4 June 1989 Income Tax Severed Letter 5-7336 - [Subsection 55(2) of the Income Tax Act—Safe Income]

The dividend payment would be taken in to consideration in any future calculation of safe income. ...

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