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Miscellaneous severed letter

7 August 1990 Income Tax Severed Letter - Administrative position concerning application of subsection 15(1) of the Income Tax Act as it relates to “sole purpose corporations” holding U.S. residential real estate

In addition we note that depending upon the particular facts the issue of the preferred shares may contravene the condition (number 3) that the only transactions of the corporation relate to its objective of holding property for the personal use or enjoyment of the shareholder. ...
Miscellaneous severed letter

10 January 1992 Income Tax Severed Letter 9133145 - Deferred Salary Leave Plan

Paquette at (613) 954-2522 or to the following address: Coverage Policy and Legislation Section Source Deductions Division Revenue Canada Taxation 875 Heron Road Ottawa, Ontario K1A 0L8 If the Plan is adjusted to correct the aforementioned problems it is our opinion that it will not contravene the provisions in Regulation 8801. ...
Miscellaneous severed letter

2002 Income Tax Severed Letter 2002-013816D - AMENDMENT OF QLP RULING

Ruling C of the Ruling Letter was that "The terms of the Draft Agreement will not cause the Partnership to contravene the condition described in paragraph 5000(7)(d) of the definition of "qualified limited partnership" that the interests of the limited partners are described by reference to units of the partnership that are identical in all respects. ...
Miscellaneous severed letter

5 October 1988 Income Tax Severed Letter 7-2994 - [881005]

XXXX In our research, we failed to determine the existence of such a policy but did, in fact, note a number of Rulings Directorate opinion letters which would contravene such a rule. ...
Miscellaneous severed letter

15 November 1990 Income Tax Severed Letter

Thus use of political donations in the manner described above would not only be inconsistent with the intent of the political contribution tax credit provisions of the Income Tax Act but could in some cases also contravene the NPO provisions of the Income Tax Act or certain provisions of the Canada Elections Act. ...
Miscellaneous severed letter

27 September 1985 Income Tax Severed Letter B-6292 - [Paragraphs 8(1)(f) and (h)]

As you know, in determining income from business, a taxpayer may deduct any reasonable expense incurred for the purpose of earning such income that does not contravene the rules prohibiting deductions as set out in sections 18 and 19 of the Act or as permitted by section 20 of the Act. ...
Miscellaneous severed letter

15 October 1986 Income Tax Severed Letter 5-1732 - []

This debit balance may be construed as a loan which would contravene subsections 146(4), 146(10) or 146(13) of the Act. ...
Miscellaneous severed letter

22 June 1989 Income Tax Severed Letter AC80289 - Deductibility of Sales Tax Penalties

" It is your view that allowing the penalty in the present case would not contravene public policy. ...
Miscellaneous severed letter

30 April 1987 Income Tax Severed Letter

We are of the views that our interpretation of Reg. 1205 (b) does not contravene the rule expressed by Willie J. in Philips v. ...
Miscellaneous severed letter

14 September 1992 Income Tax Severed Letter 2M01980 - Income Earned or Realized

Subsection 55(2), however, does not require that a subsidiary that has income earned or realized in respect of the shareholder of the parent pay that amount as a dividend to the parent in order that a dividend paid by the parent not contravene the subsection. ...

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