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The majority of the voting shares of Company X are owned by company Y and will continue to be so owned throughout the time that the Plan is in operation. 2.      ... Such purchase by an Employee may give rise to a taxable benefit pursuant to section 6 or section 7 of the Act. 3.      ... Under the Plan, the Employees also have the option of selling shares issued under the Plan directly to Company X rather than to Sidecar Co. 4.      ...

18 October 1990 Administrative Letter 59586 F- Impact of Partnership on Pre-acquisition Losses Unedited CRA Tags 111(5), 87(2.1) 24(1) 5-9586   L.A. ... Situation No. 1 1.     Company B acquired all the shares of Company A in an arm's-length transaction. 2.      ... The income and losses of the partnership, based on the relative net fair market values of the assets contributed by Companies A and C, are allocated two-thirds to Company A and one-third to Company C.       ...

Leung   (613) 957-2116 March 12, 1990 Dear Sirs: Re: Subsections 49(1) and 85(1) of the Income Tax Act (the "Act") We are writing in response to your letter of December 6, 1989 wherein you requested our view as to whether subsection 85(1) of the Act would be applicable to the granting of an option to which subsection 49(1) of the Act applies in the following hypothetical situation as described in your letter. 1.      ... "Taxable Canadian corporation" and "cost amount" have the meanings assigned by paragraph 89(1)(i) and subsection 248(1) of the Act, respectively. 2.      ... A. will receive shares of Subco having a fair market value of $10. 3.      ...

19 November 1990 Administrative Letter 900316 F- Ontario Foreign Tax Credit- Form T2036 Unedited CRA Tags n/a 24(1) 900316   G. Arsenault   (613) 957-2126 19(1) November 19, 1990 Dear Sir: Re:  Ontario Foreign Tax Credit- Form T2036 This is in reply to your letter dated March 26, 1990 whereby you inquired as to whether there is an error in Form T2036 and in the manner in which the Department calculates the Ontario Foreign Tax Credit. ... Yours truly, for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch c.c.       ...

This remains so even if a proposed plan meets all of the requirements for registration set out in IC 72-13R8. 4.     GAAR is not of relevance at the registration stage but may become relevant in considering what action can be taken in respect of plans that have been registered. 5.      ... It is possible for a taxpayer to seek a writ of certiorari against the Minister in these circumstances. 6.      ...

Our understanding of the facts in this case is as follows: 24(1) 24(1) 4.      ... The reasons for our views are as follows: 1.     The taxpayer was, pursuant to a court order, required to pay 24(1)to his spouse. ... This, in our view, indicates that the spouse used her discretion to direct the taxpayer to make the mortgage payment on her behalf.  3.      ...

20 September 1989 Administrative Letter 74326 F- Thin Capitalization Rules- IT-59R3 Unedited CRA Tags 18(4)   September 20, 1989 TO- Publications Division FROM- Specialty Rulings   Directorate Mr. ... Tevlin Director 957-2118   File No. 7-4326 SUBJECT:  Interpretation Bulletin IT-59R3 We are writing to advise you of our concern regarding the comments in paragraph 3 of Interpretation Bulletin IT-59R3 as they relate to the "thin capitalization rules" as determined in subsection 18(4) of the Act. 24(1) 21(1)(a) M.A. ...

30 October 1989 Administrative Letter 8160016 F- Minister's Correspondence Unedited CRA Tags n/a   October 30, 1989 TO- HEAD OFFICE FROM- Technical  Enquiries and Taxpayer Interpretations Division Assistance Division D. Lanos Attention: Pauline McNally (613) 957-9231 Director   Y.S. 8160016 SUBJECT: MINISTER'S CORRESPONDENCE 19(1) Further to your memorandum of August 19, 1988, the enclosed Order in Council P.C. 1989-1634 dated August 24, 1989, was issued authorizing the remission of federal tax of 19(1) for 1977 and related interest.  ... Cockell DirectorTechnical Interpretations DivisionLegislative and Intergovernmental Affairs Branch c.c.:     Saskatoon D.O.Attention: Sandra Dodge Public Affairs c.c.:     Revenue Programs Division Enclosures ...

1 September 1989 Administrative Letter 74246 F- Revision of IT-146R3 Unedited CRA Tags n/a   September 1, 1989 Roy C. ... Leung   957-2116 Attention:  T. Bryant Subject:  Interpretation Bulletin Project Number 1963 Revision of IT-146R3 This memorandum is in response to yours dated August 16, 1989. Our comments on version 5 of the above-noted Project (the "Project") are as follows: 1.      ...

13 December 1990 Administrative Letter 902776 F- Deductibility of Travel Expenses Unedited CRA Tags 18(1)(a), 18(1)(h) 19(1) 902776   R.B. Day   (613) 957-2136 December 13, 1990 19(1) We are writing in reply to your letter of September 11, 1990, in which you requested an advance income tax ruling with respect to the deductibility of travel expenses incurred by your corporations. ... Yours truly, for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch Attachments c.c.       ...