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Miscellaneous severed letter

23 September 1996 Income Tax Severed Letter 9616357 - Meals and allowances

" The first consideration should therefore be to determine the purpose of the legislation, whether as a whole or as expressed in a particular provision. ...
Miscellaneous severed letter

7 August 1990 Income Tax Severed Letter - Technical interpretation in connection with a hypothetical situation in which arm's length partners agree to allocate partnership income and loss

Farmout The hypothetical situation appears to be similar to a widespread farmout arrangement whereby a farmee, Partner B, would acquire an interest in a farmor's, Partner A's, Canadian resource property and in consideration for such interest, Partner A would receive, inter alia, an interest in Partner B's depreciable property. ...
Miscellaneous severed letter

17 May 1990 Income Tax Severed Letter RRRR299 - Capital cost allowance of electrical generating equipment, steam generating equipment and cogeneration stations

Free Waste Heat- Clause (d)(ii) B of Class 34 In interpreting statutes of law, all words and terms must be taken into consideration. ...
Miscellaneous severed letter

7 September 1990 Income Tax Severed Letter - Application of subsections 110.6(8) and 110.6(9) of the Income Tax Act and section 6205 of the Regulations in various scenarios

X transferred all of his shares of Opco to Holco on a tax-deferred basis pursuant t subsection 85(1) and received special freeze shares as consideration therefor. ...
Miscellaneous severed letter

7 August 1991 Income Tax Severed Letter - Stock Option Benefit

In reaching this conclusion, the Court stated: "Where the income under consideration is part of the normal business activity of a company and it is inextricably linked with an active business it is considered active business income. ...
Miscellaneous severed letter

17 May 1990 Income Tax Severed Letter AC59241 - CCA Class 34 in Relation to Cogeneration Stations

Free Waste Heat- Clause (d)(ii) B of Class 34 In interpreting statutes of law, all words and terms must be taken into consideration. ...
Miscellaneous severed letter

15 April 1985 Income Tax Severed Letter

XXXX had submitted a position paper on the matters and asked that the matters be referred to Head Office for consideration. ...
Miscellaneous severed letter

9 September 1986 Income Tax Severed Letter

Barfried Enterprises Ltd. [1963] S.C.R. 570 at p.575]; 2. interest is the return or consideration or compensation for the use or retention by one person of a sum of money belonging to another [Reference re Validity of Section 6 of the Farm Security Act, 1944, of the Province of Saskatchewan (1947] S.C.R. 394 at pp.411-412]; and 3. interest is referable to a principal sum in money or an obligation to pay money [Reference re Farm Security Act, supra., at pp.411-412; see D.S. #6022-9(b)]. ...
Miscellaneous severed letter

23 October 1991 Income Tax Severed Letter F

Cela suppose, en particulier, que le but de la disposition en cause doit être pris en considération. ...
Miscellaneous severed letter

26 May 1989 Income Tax Severed Letter 5-7327 - [890526]

At that meeting three other issues were raised but it was agreed that they should more appropriately be submitted to this office for consideration. ...

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