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10 October 1989 Ruling 89M10073 - Révision du guide d'impôt - revenus de personnes décédées

Nous avons réexaminé le guide en question et avons relevé d'autres points que vous pourriez prendre en considération. ...

4 June 1991 Ruling 911003 F - Shareholder Benefits - Intercompany Loans

In this situation, the payer corporation has provided valuable consideration with no reasonable expectation of repayment. ...

7 November 1990 External T.I. 9022185 F - Associated Corporations - Meaning of "Unpaid Dividends" and "Accrued Unpaid Dividends"

Please note that, in the majority of corporations' certificates of constitution, the share legal rights would provide for the payment upon redemption, repurchase or liquidation, of an amount equal to the consideration for which the share has been issued and any amount of dividends declared and not paid. 21(1)(b) R.J.L. ...

30 October 1990 External T.I. 90M10405 F - Gifts to a Municipality

IN GENERAL, A GIFT IS A VOLUNTARY TRANSFER OF PROPERTY WITHOUT CONSIDERATION. ...

14 February 1991 Ruling 903521 F - Medical Expenses

Consequently we have forwarded a copy of your letter and our reply to officials of the Department of Finance for their consideration. ...

19 June 1990 Internal T.I. 900429 F - Non-profit Corporations

Our Comments Questions relating tax considerations of a particular taxpayer should be addressed to your local District Taxation Office. ...

19 November 1990 External T.I. 9028715 F - Non-profit Organizations

An organization's status for purposes of paragraph 149(1)(1) of the Act would be determined on the basis of the facts and details respecting its organization and its actual activities and the GST election should not be a consideration. ...

19 October 1990 External T.I. 52250 F - Grandfathering Provision - Section 19 Amendments

Provided that our understanding of the facts as described herein is correct, it is our opinion that an acquisition of rights to produce and publish issues of the 24(1) The July 13, 1990 Draft Amendments to section 19 of the Act do not contain any accompanying grandfathering provisions which in our view would be necessary before any consideration of exemption from the proposals is possible. ...

1 September 1989 Administrative Letter 74246 F - Revision of IT-146R3

Otherwise it would not be appropriate to refer to that IT in paragraph 6 of the Project. 21(1)(b) We have also suggested other minor editing changes to the Project for your consideration as noted thereon. ...

25 February 1991 Ruling 902303 F - Canada-U.K. Income Tax Convention - Mines and Mineral Reserves

A determination of from what shares derive their value or the greater part of their value is essentially a question of fact that can only be determined after consideration of all relevant facts including the manner in which the various assets of the company have been financed. ...

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