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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. ...

3 March 1992 Income Tax Severed Letter 9204185 - Pension splitting marriage breakdown — source deductions

Bissonnette (613) 957-2136 Director 920418 XXX Pension Splitting on Marriage Breakdown Application of 56(1)(a)(i) and 153(1) We are forwarding, for your consideration and reply, the February 6, 1992, Round-Trip memorandum from Source Deductions Division in the Scarborough District Office and the accompanying letter from the taxpayer's representative dated January 14, 1992. ...

27 September 1989 Income Tax Severed Letter 7-4343 - Interpretation Bulletin—Project Number 1719—Crown Corporation Employees Abroad Revision of IT-106R

We offer the following comments for your consideration: 1. Re: "Summary" Inserting a) "factually resident in Canada or they may be" after "may be" (line 3); b) a period after "Canada" (line 3); and c) "Both factual and deemed residents of Canada are" after "and thus" (line 3) and deleting "and thus" (line 3) may provide greater clarity. 2. ...

19 September 1989 Income Tax Severed Letter 5-8466 - Deductibility of interest on money borrowed by a partnership to return capital to its partners

The comments expressed 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. ...

3 October 1989 Income Tax Severed Letter 5-8480 - Residence of an estate

Since this enquiry is in respect of a factual situation, we are forwarding it for your consideration and reply. ...

12 December 1989 Income Tax Severed Letter 5-8895 - Interpretation of the words in subparagraph 50(1)(b)(iii) that precede clause (A) of the subparagraph

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

30 May 1990 Income Tax Severed Letter 9007005 - Tax treatment of payments made from a registered retirement income fund to a person resident in Ireland

Such consideration would be done by the relevant district office where the transaction is completed or by this office where the transaction is proposed. ...

Income Tax Severed Letter AC74668AF F

En conséquence, nous avons transmis votre demande à cette dernière division pour sa considération. ...

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