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4 December 1989 Income Tax Severed Letter 5-9089 - Clarification of the retirement compensation arrangement provisions

In the situation described by you, the determination as to whether these arrangements would by RCAs would have to be made after consideration of the relevant facts. ...

19 September 1989 Income Tax Severed Letter 5-8568 - Whether an annuitant under a registered retirement savings plan may deduct administration fees charged by brokers for the management of registered retirement savings plan investments

The comments set out in this letter are of a general nature only and do not take into account considerations that might arise in the context of specific transactions or events. ...

Income Tax Severed Letter AC74668F F

En conséquence, nous vous transmettons ladite demande du Bureau de district de Montréal pour votre considération. ...

23 May 1990 Income Tax Severed Letter 7-4789 - Whether, in respect to vessels, the term “in Canada” as used in the definition of “qualified property” in subsection 127(9) of the Income Tax Act includes waters that are 12 to 200 miles off the coast of Canada

Pursuant to the definition of qualified property, the relevant consideration is the primary purpose for which an asset is acquired, and the vessels referred to apparently were not acquired to be used in Canada primarily for the purpose of fishing (or processing fish). xxxxx for Director Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

18 November 1991 Income Tax Severed Letter 912927 - Foreign service relocation allowance

Buenger agreed to provide additional background material for out further consideration. ...

17 July 1989 Income Tax Severed Letter 7-4125 - Whether subsections 85(1) or 15(1) apply in a particular transfer of property

We agree with your conclusion to disallow the application of subsection 85(1) of the Act to the sale of the building to XXX in 1985 on the basis that the relevant shares to be given as consideration were never authorized or issued. ...

25 November 1981 Income Tax Severed Letter RCT 7-1480

XXX Subsection 42(1) of the BC Act provides "no shares with par value shall be allotted or issued except at a price or for a consideration at least equal to the product of the number of shares allotted or issued multiplied by their par value. ...

19 September 1989 Income Tax Severed Letter F-3249

19 September 1989 Income Tax Severed Letter F-3249 Unedited CRA Tags 48(1)(a) Paragraph 48(1)(a) Elections- Prescribed Form We have the following comments for your consideration which we discussed via the telephone on September 11: (1) In the first paragraph you have the taxpayer electing immediately before ceasing to be resident. ...

15 September 1981 Income Tax Severed Letter RCT-0245 F

The investors in consideration of the partnership interest make a payment of cash and issue a 30 month interest bearing note payable to the Canadian partnership. ...

12 September 1989 Income Tax Severed Letter 7-4287 - Whether a specific advance income tax ruling is suitable for publication

We have edited a copy of your draft publication which is enclosed for your consideration. ...

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