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11 September 1989 Income Tax Severed Letter 5-8350 - Definition of “small business corporation” where corporation's only asset is an interest in a partnership

" Accordingly, in the situation you have described, it is the corporation's proportionate share of the fair market value of the underlying assets of the partnership that is taken into consideration in determining if the previously mentioned requirement in the definition of "small business corporation" has been satisfied. ...

28 June 1989 Income Tax Severed Letter 5-8264 - Transfer of U.S. social insurance benefits to registered retirement savings plans—our letter No. 5-6698 dated October 21, 1988

Upon further consideration, we have concluded that the full amount of the Benefits must be brought into income under the provisions of subparagraph 56(1)(a)(i) of the Act but an offsetting deduction for 1/2 of the amount would be allowed under subparagraph 110(1)(f)(i) of the Act for the amount not taxable under the Convention. ...

2 January 1980 Income Tax Severed Letter RCT 7-1011 F

We also point out that, even if the cooperative were to amend its memorandum of association to convert from an association without share capital to one with share capital, in view of the fact the property is to pass for no consideration application of paragraph 85(1)(e.2) would have to be considered. ...

14 February 1990 Income Tax Severed Letter AC74626 - Admissibility of Universal Life Policies as Charitable Donations

However this is a question of fact, that can only be determined after consideration of the circumstances of a particular situation. ...

29 December 1989 Income Tax Severed Letter 5-8841 - [Group Sickness or Accident Insurance Plan]

XXX While the income tax implications with respect to any particular arrangement can only be determined after consideration of the specific facts we are able to provide you with the following general comments. ...

16 February 1990 Income Tax Severed Letter ACC8758 - Canada-United States Social Security Agreement

We trust you will give this request favourable consideration. Yours sincerely, C. ...

8 September 1989 Income Tax Severed Letter 5-8079 - [851031]

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 shares sold. ...

16 February 1990 Income Tax Severed Letter ACC8755 - Canada-United States Social Security Agreement

We trust you will give this request favourable consideration. Yours sincerely, C. ...

26 June 1990 Income Tax Severed Letter ACC9576 - Pension and Annuity Payments under Canada-Trinidad and Tobago Income Tax Convention

The matter is presently under consideration. We trust our comments are of assistance to you. ...

2 February 1990 Income Tax Severed Letter AC32703 - Advance Income Tax Ruling Request

Eisner 613 957-2138 February 2, 1990 Re: 24(1) Advance Income Tax Ruling Request In your letter of January 2, 1990, you advised us that certain information, which we require in order to proceed with our consideration of your advance income tax ruling request, will not be available until June, 1990. ...

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