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Technical Interpretation - Internal
11 June 1996 Internal T.I. 9620810 - WIND-UP BUMP DIVIDENDS
The Department's position is, however, that a corporation, the control of which was acquired from an arm's-length party, is considered to have been acquired from that party. ...
Ruling
30 November 1995 Ruling 9622013 - RETIRING ALLLOWANCE, PROFESSIONAL CORPORATION
Additional Information To the best of your knowledge and that of XXXXXXXXXX and the Employer, none of the issues involved in this ruling are being considered by a District Tax Services Office or Taxation Centre in connection with a return already filed and none of the issues are under objection. ...
Technical Interpretation - External
3 October 1996 External T.I. 9632805 - RRIF ADMINISTRATION & INVESTMENT MANAGEMENT FEES
The payment will not be considered the payment of an amount to a RRIF. ...
Ruling
30 November 1995 Ruling 9620593 - TAXABILITY OF SETTLEMENT PAYMENT
XXXXXXXXXX XXXXXXXXXX 8.To the best of your knowledge and that of XXXXXXXXXX management, none of the issues or matters concerning the ruling requested is being considered by a Taxation Services Office or a Taxation Centre with respect to a return already filed nor are any of the issues the subject of a Notice of Objection or Appeal by XXXXXXXXXX. ...
Ruling
30 November 1995 Ruling 9623193 - WITHOLDING TAX ON INTEREST
To the best of your knowledge and that of the taxpayer involved, none of the issues raised in this request are being considered by a Tax Services Office or Taxation Centre in connection with an income tax return already filed or is the subject of a notice of objection or is under appeal. ...
Technical Interpretation - External
24 October 1996 External T.I. 9634035 - RETIRING ALLOWANCE AFFILIATE AMALGAMATION
Principal Issues: Where an employer corporation is amalgamated with another corporation under section 87 of the Act would the amalgamated corporation be considered an affiliate of the employer corporation for purposes of retiring allowance payment? ...
Technical Interpretation - External
24 October 1996 External T.I. 9634255 - ACQUIRING HOME MORE THAN 5 YEARS BEFORE DATE
You ask whether the amount withdrawn is disqualified from being an "eligible amount" by virtue of paragraph (d) of the definition by reason solely of the fact that the individual and his spouse acquire the home previously owned in 1988 and therefore could be considered to have "acquired the qualifying home more than 30 days before" the date of withdrawal. ...
Technical Interpretation - External
26 November 1996 External T.I. 9634635 - STANDBY AND FUNDING FEES
However, where each drawdown is evidenced by a promissory note so that there are separate obligations each satisfying the requirements of subparagraph 212(1)(b)(vii) of the Act, the standby fees and funding fees that are considered to relate to the exempt loan will also be exempt from withholding tax. ...
Technical Interpretation - External
6 December 1996 External T.I. 9633735 - CAN EMPL'EE DEDUC EX WHEN EMP'ER CHARGES ROOMBOARD
If the allowance is a reasonable approximation of what the employee is likely to spend for the expense or expenses covered by the allowance, then the allowance will be considered reasonable. ...
Technical Interpretation - External
11 December 1996 External T.I. 9637375 - NO 1/3 EXEMPT ON SLRY PAID TO XXXXXXXXXX
In addition to the foregoing, it is our view that XXXXXXXXXX cannot be considered to be either a provincial legislature, an incorporated municipality or a governmental body similar to a municipal board, municipal commission, municipal corporation or school board, based on the relevant legislation. ...