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Technical Interpretation - External

24 November 1994 External T.I. 9424705 - PRINCIPAL RESIDENCE

We also note that if the issue of subdivision restrictions or minimum lot sizes is to be considered, the details of the restrictions and zoning should be provided. ...
Technical Interpretation - External

9 December 1994 External T.I. 9425665 - CAPITAL GAINS ELECTION

With respect to your question regarding the revised adjusted cost base of property subject to an election, according to subparagraph 110.6(19)(a)(ii) of the draft legislation, where an election is filed, the property covered by the election is considered to have been reacquired by the elector at a cost equal to:? ...
Technical Interpretation - External

22 November 1994 External T.I. 9429385 - USE OF A LODGE

The first would be whether a particular property would be considered to be a "lodge", and the request for such a determination would have to be made by the owner of that property. ...
Ministerial Correspondence

7 April 1994 Ministerial Correspondence 9410764 - INDIANS

Employment income for duties performed off a reserve by an Indian living on reserve will normally be exempt where the employer is resident on reserve, except where it can reasonably be considered that one of the main purposes for the existence of the employment relationship is to establish a connecting factor between the income in question and a reserve. ...
Ministerial Letter

31 October 1994 Ministerial Letter 9426738 - INDIANS - WHAT CONSTITUTES A RESERVE

In addition, the following settlements, situated in Ontario, are deemed to be reserves: Long Dog Lake Settlement (Wawakapewin) Kee-Way-Win Settlement Savant Lake Settlement (Saugeen Nation) McDowell Lake Settlement Slate Falls Settlement (New Slate Falls) Aroland Settlement Grandmother's Point Settlement (Landsdowne House) Webequie Settlement Only the lands described above are considered to be "reserves" in Ontario. ...
Technical Interpretation - External

7 November 1994 External T.I. 9427005 - QUALIFIED INVESTMENTS FOR AN RRSP AND ARM'S LENGTH

Reasons FOR POSITION TAKEN: Routine XXXXXXXXXX 5-942700 Attention: XXXXXXXXXX November 7, 1994 Dear Sirs: Re: Qualified Investments in a Registered Retirement Savings Plan (RRSP) This is in reply to your facsimile of September 30, 1994 requesting our opinion on whether or not a particular mortgage would be considered an arm's length transaction and whether or not it would be a qualified investment for an RRSP. ...
Technical Interpretation - External

17 January 1995 External T.I. 9427625 - EMPLOYMENT EXPENSE AND TEACHERS' SUPPLIES

Although ordinarily this requirement necessitates that there be an express requirement within the terms of a written contract of employment, it is the Department's general position that this requirement may also be considered to have been satisfied where it is tacitly understood by the employer and the employee that the supplies be provided by the employee. ...
Technical Interpretation - External

13 January 1995 External T.I. 9430035 - EBP DEFERRED PAYOUT OPTIONS

Constructive receipt is considered to apply in situations where an amount is credited to an EBP beneficiary's debt or account, set apart for the EBP beneficiary or otherwise made available to the EBP beneficiary without being subject to any restriction concerning its use. ...
Technical Interpretation - External

20 January 1995 External T.I. 9432445 - RETIRING ALLOWANCE - TRANSFER TO RRSP

St-Amour Attention: XXXXXXXXXX January 20, 1995 Dear Sirs: Re: Retiring Allowance- subparagraph 60(j.1)(v) of the Income Tax Act (the "Act") This is in response to your letter of December 9, 1994, in which you ask whether the years of service with another employer which participates in the Ontario Municipal Employees' Retirement System ("OMERS") can be considered for purposes of calculating the number of years when determining the eligible portion of a retiring allowance transferred to a registered retirement savings plan ("RRSP"). ...
Technical Interpretation - External

16 January 1995 External T.I. 9425675 - DEDUCTIBILITY OF UNION DUES

Position TAKEN: No Reasons FOR POSITION TAKEN: The dues paid into the scholarship would be considered to have been levied for a "purpose not directly related to the ordinary operating expenses of the... trade union to which they were paid" for the purposes of paragraph 8(5)(c). 942567 XXXXXXXXXX M. ...

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