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11 January 1990 Ruling HBW4125U31 F - Permanent Establishment in Canada of Non-resident Corporation

Normally, in making such a determination, the Department would give consideration to the commentary on paragraph 3 of Article V in the Model Double Taxation Convention On Income and On Capital-Report of the OCED Committee on Fiscal Affairs 1977. ...

26 February 1990 Internal T.I. 90M02419 F - Adverse Decision of the Tax Court of Canada

With respect to the Decisions Communiqué which you propose to issue, we offer the following comments for your consideration: (i) Add the word "EXPENSES" after "MOVING" at the end of line 2. ...

25 January 1990 Ruling 90M01411 F - Remission Order

The Ontario Ministry of Revenue will be provided with the information necessary for their consideration of a remission of provincial income tax. ...

10 June 1991 Internal T.I. 910249 F - Request for Registration as an "Approved" Institute

In order to complete our consideration of this request we require the following: 1. ...

16 October 1989 Ministerial Correspondence 89M10354 F - Remission of Tax

On your behalf, I will ensure that the Manitoba Ministry of Revenue is provided with information necessary for their consideration of a remission of provincial income tax. ...

21 March 1990 Administrative Letter 90M03256 F - Request for Remission of Tax

However, after a careful consideration of the matters raised by you, I regret to advise that the measure of relief you are seeking cannot be granted. ...

5 December 1989 Ruling 74353 F - Capital Loss on Winding-up of Subsidiary

In our view, this paragraph implies that if there are other considerations with respect to a loss (e.g. subsections 88(1.1) and 80(3)), the comments in the paragraph are not applicable. ...

22 January 1991 Ministerial Correspondence 9101784 F - Non-Registered Annuities

This matter has previously been referred to Mary Loveday of your division for consideration. 19(1) principal concern is that the Department is not administering the tax law with respect to non-registered annuities consistently. ...

8 September 1989 Internal T.I. 58079 F - Sale of Shares to Corporation

A") of a corporation ("Aco") intends to sell, at fair market value, his class A common shares of Aco to Aco in consideration for class B common shares of Aco which have the same fair market value and stated capital as the class A common share sold. ...

7 November 1990 Ruling 90M11381 F - Tax Shelter Reporting Rules

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). ...

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