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7 September 1990 Income Tax Severed Letter - Whether subsections 20(1) and 20(1.2) of the ITAR will be applicable to depreciable property transferred to and from a partnership under subsections 97(2) and 98(3), respectively, of the Income Tax Act

For all other provisions of the Act, including consideration of the application of subsection 20(1.2) of the ITAR, the actual date of acquisition is applicable. 3. ...

16 May 1990 Income Tax Severed Letter RRRR339 - Whether certain properties are inventory

Short FILE DOSSIER 8-0347 SUBJECT: OBJET: Re: xxxxx Notices of objection 1983 and 1984 We are writing in response to your memorandum of January 15, 1990 in which you have requested our further consideration and comments with respect to a memorandum we issued on January 13, 1989, to the Ottawa District Office. ...

22 May 1990 Income Tax Severed Letter RRRR289 - Review of Corporate Reorganizations Course Material — Lesson 5 Surplus Strips

However, if an election is made pursuant to subsection 85(1), the agreed amount cannot be less than the fair market value of the non-share consideration pursuant to paragraph 85(1)(b). ...

7 July 1991 Income Tax Severed Letter - Several issues pertaining to subparagraph 212(1)(b)(vii)

" Answer of Question 9 A definitive opinion in respect of a matter of this kind can only be formulated after a determination and consideration of all relevant facts. ...

7 September 1990 Income Tax Severed Letter - Deduction of large expenses that are incidental to the business

Kirk (1990) A.C. 588, a statutory provision under consideration provided for a tax on income arising from any trade carried on in New South Wales or derived from lands of the crown and stated that no tax shall be payable in respect of income earned outside the Colony. ...

7 August 1990 Income Tax Severed Letter - Amount of business limit

However, due to the fact that the words being interpreted by the court, i.e. the corporation, are different from those currently under consideration, the outcome of this case is not considered as a precedent in interpreting these words. ...

7 August 1990 Income Tax Severed Letter - Part I.3 tax on large corporations

Upon the wind-up, the acquiring corporation increases the book value of the assets of the acquired corporation by the difference between the consideration paid for the shares of the acquired corporation and book value of those assets. ...

7 September 1991 Income Tax Severed Letter - Determination of Residency

The temporary nature of the trip and ties within Canada have become the vital considerations. ...

7 September 1991 Income Tax Severed Letter - Qualified Small Business Corporation Share

In particular, we have insufficient information to enable us to determine how the capital gains will arise; however, in general, by virtue of paragraphs 86(1)(b) and (c) no capital gains will arise on a section 86 reorganization of capital where the only consideration received by the taxpayer is shares of another class of the capital stock of the corporation. ...

7 August 1991 Income Tax Severed Letter - Income Allocated to a Retiring Partner

The income calculated by a partnership pursuant to paragraph 96(1)(f) of the Act must take into consideration the partnership's election under paragraph 34(a) of the Act. ...

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