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18 December 1989 Administrative Letter 59166 F- Redemption of Shares at less than FMV Unedited CRA Tags 40(1), 54 proceeds of disposition, 69(1)(b), 84(3), 84(9), 110.6(7) 19(1) File No. 5-9166   S. Leung   (613) 957-2116 December 18, 1989 Dear Sirs: Re:  Paragraph 69(1)(b) and subsection 84(3) of the Income Tax Act (the "Act") We are writing in response to your letter of November 24, 1989 wherein you requested our opinion as to whether paragraph 69(1)(b) of the Act would apply to the following situation which was outlined in your letter. Situation 24(1) Our Comments It is the Department's view that paragraph 69(1)(b) of the Act will apply to a disposition of shares of a corporation which are disposed of in a manner as described in subsection 84(9) of the Act, if (i)     the shareholder who disposes of the shares is not dealing at arm's length with the corporation, and (ii)     the proceeds of disposition of the shares (i.e. the redemption price) is less than their fair market value at the time of their disposition, notwithstanding that subsection 84(3) of the Act might also apply to the acquisition of its own shares by the corporation.  ...

14 August 1990 Administrative Letter 59836 F- Capital Canadian Property Unedited CRA Tags 110.6, 248(1) taxable Canadian property 24(1) 5-9836   M.P. Sarazin   (613) 957-2125 Attention: 19(1) August 14, 1990 Dear Sirs: This is in reply to your letter of March 22, 1990 in which you requested our interpretation regarding the application of subsection 110.6(5) of the Income Tax Act (the "Act") to the situation where a non-resident individual proposes to dispose of taxable Canadian property within the meaning assigned under subsection 248(1) of the Act and also proposes to become a Canadian resident in that same year. ... You may wish to refer to page 80 of the Technical Notes to a Bill Amending the Income Tax Act and Related Statutes issued by The Honourable Michael Wilson, Minister of Finance, November 1985 where it states:      "New subsection 110.6(13) of the Act provides that for the purposes of the capital gains exemption no amount is computed under paragraph (3)(b) for a period throughout which the individual was not resident in Canada. ...

For purposes of the Act the complete definition of a retiring allowance is:      "... an amount (other than a superannuation or pension benefit, an amount received as a consequence of the death of an employee or a benefit described in subparagraph 6(1)(a)(iv)) received      (a)  upon or after retirement of a taxpayer from an office or employment in recognition of his long service, or      (b)  in respect of a loss of an office or employment of a taxpayer, whether or not received as, on account or in lieu of payment of, damages or pursuant to an order or judgment of a competent tribunal by the taxpayer or, after his death, by a dependant or a relation of the taxpayer or by the legal representative of the taxpayer". ...

Partner B deals at arm's length with Partner A and Subco. 3.      ... Subco will have no material assets or liabilities, its role being to join with Partner A to create the partnership. 5.      ... Shortly thereafter the partnership's first fiscal year will end. 6.      ...

18 August 1989 Administrative Letter 57806 F- Taxation of Deferred Annuities Unedited CRA Tags 12.2, 212(1)(o), 48(3), 148, 56(1)(d.1), 60(a)ITR 201(5), 202(2), 304, 305 19(1) File No. 5-7806   Firoz Ahmed   (613) 957-2092 August 18, 1989 Dear Sirs: Re:  Taxation of Deferred Annuities This is in response to the questions raised in your letter dated March 28, 1989 and in our telephone conversation 19(1) Ahmed) of June 20, 1989 relating to the application of various provisions of the Income Tax Act (the "Act") to the situation described below. 1.      ... X in respect of such annuity contract while he is not a resident of Canada. 3.      ... You have raised the following questions: 1.     What is the effect of Mr. ...

The credit will be available for 1988. 2.     The disability begins in May 1988 and ends in January 1989.  ... You sought our views on the following two examples on the last page of your memorandum: 1.      ... Our opinions are: 1.     The child would qualify if, when the impairment was diagnosed, it was reasonably expected to last for a continuous period of at least 12 months. 2.      ...

17 January 1990 Administrative Letter 74386- Déduction pour emploi à l'étranger Unedited CRA Tags 122.3(1)   Le 17 janvier 1990 BUREAU DE DISTRICT BUREAU PRINCIPAL DE MONTRÉAL Section des services   bilingues Jacqueline Donaldson Andrée Simard Déductions à la source (613) 957-8981 164-2-5   File No. 7-4386 Objet: 24(1) La présente note de service est en réponse à votre note aller-retour du 26 septembre 1989 en vertu de laquelle vous nous demandez de vous confirmer que 24(1) Après analyse du paragraphe 122.3(1) de la Loi de l'impôt sur le revenu (LIR) et de nos dossiers de recherches, nous constatons que 24(1) Nous attirons votre attention sur le fait, qu'à cet égard la législation fédérale diffère de la législation du Québec [art. 79.1 de la Loi sur les impôts (LI)]. ...

23 October 1991 Administrative Letter 912346 F- Penalty Provisions in Connection with Collection Procedures Unedited CRA Tags 239(1(d),162(7)(b), 159(2),159(3) Application of 239(1(d) & 162(7)(b) to 159(2) & (3) Further to our telephone conversation of October 18, 1991, withEr. ... We examined our research files and found that the possibility of applying these penalty provisions in 159(2) & (3) situations had never been addressed by this Directorate. ...

28 March 1990 Administrative Letter F3421 F- Block Averaging and Minimum Tax Unedited CRA Tags n/a   March 28, 1990 Mr. ... Burnett   (957-2078)   File No. F-3421/3576 Block Averaging and Minimum Tax This is in response to your memoranda of November 21, 1990 and March 5, 1990 concerning the above subject. ...

15 August 1989 Administrative Letter 74116 F- Retiring Allowances Unedited CRA Tags n/a   August 15, 1989 Head Office Financial Industries Source Deductions Division Division Research and Enquiries Section Rulings Directorate   Wayne C. ... McDonald 957-3499   File No. 7-4116 Subject:  24(1) and 19(1) Your File: HAK-4940-1 RE-2083 (J.W. ...