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2 January 1990 Income Tax Severed Letter ACC8877 - Extension of Period of Detachment under Canada-U.S. Tax Agreement

We trust you will give this request favourable consideration. An early reply to this request would be appreciated. ...

25 May 1990 Income Tax Severed Letter ACC9099 - Tax Remission

However, after careful consideration of the matters outlined in his letter, I regret that I am unable to recommend the remission of his tax, penalty or interest liability. 24(1) 19(1) has been treated in a fair and reasonable manner similar to any taxpayer in like circumstances. ...

31 March 1989 Income Tax Severed Letter 5-6931 - [Bi-modal Transport Vehicles]

This matter has, therefore, been brought to the attention of the Department of Finance for their consideration. ...

8 September 1989 Income Tax Severed Letter AC58079 - 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. ...

16 October 1989 Income Tax Severed Letter ACC8539 - 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. ...

28 July 1986 Income Tax Severed Letter 5-1740 - [860728]

To simply treat the commission as a reduction of her cost of the property would be inconsistent with the fact that the full purchase price would be shown on the Affidavit of Land Transfer Tax and Value of Consideration filed with the registered deed. ...

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. ...

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