30 January 1990 Ruling HBW91381 F - Taxability of Amounts Paid to Non-resident Baseball Player

By services, 18 January, 2022
Official title
Taxability of Amounts Paid to Non-resident Baseball Player
Language
French
CRA tags
n/a
Document number
Citation name
HBW91381
Severed letter type
Ruling
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
632606
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-01-30 07:00:00",
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Main text
  January 30, 1990
Mr. M.A. Hiltz Provincial and International
Director Relations Division
Reorganizations and Non-Resident B. Fioravanti
Division 957-2073
Attention:  Ken Major
  HBW 9138-1
  HBW 9151-1     HBW 9151-2     HBW 9151-3

TAXABILITY OF AMOUNTS PAID TO NON-RESIDENT BASEBALL PLAYERS

In reply to your memorandum of February 28, 1989 concerning the above-referenced matter please find attached hereto a copy of the response we received from the Internal Revenue Service.

24(1)

If, after analyzing U.S. regulation 1.861-4(b) and Rev. Rul. 87-38, you feel that there are still areas which require clarification from the U.S., we would be pleased to pursue them. In any event, we would appreciate being advised of the guidelines which you ultimately decide upon.

C. SavageA/DirectorProvincial and International Relations Division

Enclosure

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