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Ministerial Correspondence
12 September 1990 Ministerial Correspondence 901144 F - Transfer of Depreciable Property into and Out of a Partnership
It is our opinion that subsection 103(1) of the Act will not generally apply where the allocation is consistent with a predetermined method provided for in the partnership agreement, is not a spontaneous or optional arrangement decided after or upon the termination of any given year or event, and the principal reason for the arrangement is not reasonably considered to result in the reduction or postponement of the tax that might otherwise have become payable under the Act. ...
Ministerial Correspondence
11 July 2006 Ministerial Correspondence 2006-0186661M4 - Taxation of Roth IRA
Under the October 30, 2003 version of the draft legislation, a Roth IRA would not have been considered to be an exempt foreign trust. ...
Ministerial Correspondence
2 October 1997 Ministerial Correspondence 9724014 F - AVOCATS QUI SONT NOMMÉS A LA MAGISTRATURE
PAYMENTS TO A FORMER PARTNER IN RESPECT OF GOODWILL AND WORK IN PROGRESS Work in progress and goodwill, like other properties of a partnership, are considered to be owned by the partnership for tax purposes. ... With regard to the prescribed amount, when a judge is in receipt of a salary under the Judges Act at any time in a particular year, the lesser of the amount, if any, by which 18% of this salary for the year exceeds $1,000 and the money purchase limit for the particular year is considered to be the prescribed amount in respect of the judge for the immediately following year. ...