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Under subsection 12(1) of Bill C-62, which amends the Excise Tax Act among others, as passed by the House of Commons on April 10, 1990, the GST is imposed on recipients of taxable supplies at a rate equal to 7% of the value of the consideration for the supply. ...

We have reviewed your submission with respect to the XXX plan in this light and have passed our comments on to the Halifax District Office for their consideration. ...

7 March 1991 Income Tax Severed Letter- Request for additional information to proceed with advance income tax ruling Unedited CRA Tags none Dear Sirs: Re: XXX Advance Income Tax Ruling Request We are writing with respect to your letters dated October 4 and December 17, 1990 and January 28, 1991 in which you requested an advance income tax ruling on behalf of XXX During the week of February 8, 1991 we requested a draft copy of XXX In order to proceed with our consideration of your ruling request, we would appreciate receiving this information as soon as possible. ...

Lewis, Minister of Transport, a copy of which he enclosed in his letter to my Minister, the Honourable Otto Jelinek, dated February 2, 1990, concerning a request for remission of your XXX Your case has been thoroughly reviewed and careful consideration of your situation XXX The provisions of the federal Income Tax Act and the related provincial income tax legislation, which prohibit the refund of overpayments of tax for income tax returns not filed within the three year statutory time limit, apply equally to all taxpayers. ...

Consideration of the effect, if any, of proposed changes to the Ruling, that were also requested in your letter dated October 26, 1990 has been deferred. ...

You question whether the word “person” includes a partnership, for the purposes of section 54.2 of the Act, where a partnership has disposed of property that consisted of all or substantially all of the assets used in an active business carried on by that partnership to a corporation for consideration that includes shares of the corporation. ...

In order to complete our consideration of this request we require the following: 1. ...

We feel that serious consideration should be given to an amendment to cover this deficiency in light of the fact that there is a cost base provided for in the domestic trust situation and furthermore, the Act provides a cost base to a Canadian taxpayer who has an interest in a foreign affiliate subject to the FAPI rules outside section 94. ...

We trust you will give this request favourable consideration. ...

We trust you will give this request favourable consideration. ...