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7 May 1991 Income Tax Severed Letter- Tuition Tax Credit- Private School Considered \"Other Educational Institution\" Providing Courses at the Post-secondary Level Unedited CRA Tags 118.5(1)(a)(i) XXX We are writing in reply to your letter of March 11, 1991, wherein you requested our views as to whether or not a certain private school would be considered to be an "other educational institution" providing courses at the post-secondary level as envisioned by subparagraph 118.5(1)(a)(i) of the Income Tax Act (the Act). ...

1 June 1990 Income Tax Severed Letter ACC9086- Part IV.1 and VI.1 Tax Exemption- Adjustment Formula in Share Redemption not Considered a "Specified Amount" QUESTION Subsection 191(4) requires that, for purposes of the taxes levied on certain preferred shares under Parts IV.1 and VI.1 of the Act, an amount be specified in respect of preferred shares issued in the course of a reorganization. ... In Revenue Canada's view can a formula be considered a "specified amount" for purposes of subsection 191(4) of the Act? ...

28 May 1990 Income Tax Severed Letter RRRR236- Whether partners in a hypothetical situation are considered to be “specified members” for purposes of the availability of the investment tax credits Unedited CRA Tags 248(1) Your file Votre référence Our file Notre référence 5-9378 R. ... In your letter, you requested our opinion as to whether the partners in the hypothetical situation detailed below would be considered to be "specified members" as defined in subsection 248(1) of the Income Tax Act (the "Act"). In addition, you requested our views as to what is required for a partner to be considered to be involved in the partnership business on a "regular, continuous and substantial basis". ...

8 August 1989 Income Tax Severed Letter AC73773- Mine Development Costs Considered Capital Expenditures Special Audits Division Specialty Rulings Directorate O. ... Accordingly, most of the mine development costs described in your referral would be considered capital expenditures for the purposes of the above provision. ... Therefore, since a provision for depreciation and amortization taken for accounting purposes during a particular year would not be considered a capital expenditure, it could not be argued that such an amount should be added back in arriving at the earnings of a foreign affiliate on the basis of the wording of clause 5907(2)(j)(iv)(B) of the Regualtions. ...

24 August 1989 Income Tax Severed Letter 5-8287- Timing when subsection 84(2) deems a dividend to have been paid and when, during the course of a wind-up, a shareholder is considered to have disposed of shares for the purposes of subsection 164(6) Unedited CRA Tags 164(4), 84(2) Dear Sirs: This is in response to your letter of June 14, 1989 in which you requested our opinion regarding the application of subsections 164(6) and 84(2) of the Income Tax Act (the "Act") where a capital loss arises on the winding-up of a corporation by the executor of an estate. Specifically, you requested an opinion as to when subsection 84(2) of the Act deems a dividend to have been paid and when, during the course of a wind-up, a shareholder is considered to have disposed of shares for the purposes of subsection 164(6) of the Act. ...

7 August 1991 Income Tax Severed Letter- Receipt of Rent-reduced Accommodation in Exchange for an Interest Free Loan Considered a Barter Transaction Unedited CRA Tags none Subject: XXX This is in reply to your Round Trip Memorandum of July 12, 1991 which enclosed letter from XXX Our stated opinion with regard to similar programs is that rent reductions received as a result of interest-free loans by tenants are generally subject to taxation. Receipt of free or rent-reduced rental accommodation in exchange for an interest free loan is considered to be a barter transaction. ...

24 August 1989 Income Tax Severed Letter AC58287- Winding-up- When a Dividend is Deemed Paid and a Shareholder Considered to Have Disposed of Shares 5-8287 19(1) D. ... Specifically, you requested an opinion as to when subsection 84(2) of the Act deems a dividend to have been paid and when, during the course of a wind-up, a shareholder is considered to have disposed of shares for the purposes of subsection 164(6) of the Act. ...

13 September 1990 Income Tax Severed Letter ACC9656- Indian Band Council Considered Canadian Municipality W.P. ... Anita Boscariol of Indian and Northern Affairs Canada requested that we provide you information as to whether your band council could be considered a Canadian municipality for purposes of issuing income tax receipts for charitable gifts. ...

7 July 1991 Income Tax Severed Letter- Whether a supplementary pension fund could be created and not be considered to be a retirement compensation arrangement Unedited CRA Tags 245(2) Dear Sirs: This is in reply to your letter of May 6, 1991, addressed to our Registration Directorate and referred to us for reply. You have asked if a supplementary pension fund could be created and not be considered to be a Retirement Compensation Arrangement or "RCA", if the employer's contributions thereto are included in the participating employees' income at the time of the contribution and any amounts of related investment income are included in income as they are earned. ...

7 July 1991 Income Tax Severed Letter- Whether an individual is considered to have received a benefit under subsection 15(1), 56(2) or 246(1) in a particular situation Unedited CRA Tags 15(1), 56(2), 89(1)(i), 246(1) Dear Sirs: Re: Subsections 15(1), 56(2) and 246(1) of the Income Tax Act (Canada) (the "Act") In your letter of September 20, 1990, you requested our views on the application of subsections 15(1), 56(2) and 246(1) of the Act. ... You have asked if the individual would be considered to have received a benefit under subsection 15(1), 56(2) or 246(1) in the above situation. ...