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21 June 1990 Administrative Letter 90M06396- Version française du paragraphe 96(1.8): expression "actionnaire désigné" Unedited CRA Tags 96(1.8), 248(1) associé déterminé   Le 21 juin 1990 DIVISION DES MODIFICATIONS BUREAU PRINCIPAL COURANTES Section des services   bilingues Att.: M. ... Bryson Benoit Mandeville   957-8982 OBJET:  Version française du paragraphe 96(1.8) de la Loi de l'impôt sur le revenu Il a été porté à notre attention ce qui semble être une erreur de rédaction dans la version française du paragraphe 96(1.8) ou du paragraphe 248(1) de la Loi de l'impôt sur le revenu (la "Loi"). ...

22 May 1990 Administrative Letter 74776 F- Gifts to Agents of The Crown Unedited CRA Tags 118.1, 110.1(1)(b)   May 22, 1990 Charities Division Business and General Room 5036 Division 400 Cumberland C. Tremblay   957-2095   File No. 7-4776 SUBJECT: 24(1) as Agents of the Crown This is in reply to your memorandum of March 2, 1990, wherein you request our opinion  24(1) Our Comments In order for the 24(1) to be able to treat donations received as being a gift to Her Majesty pursuant to section 118.1 or paragraph 110.1(1)(b) of the Act, the 24(1) would have to be an Agent of the Crown in right of Canada or a Province. ...

14 August 1989 Administrative Letter 74106 F- Taxability of Government Annuity Unedited CRA Tags 56(1)(a)(i)   August 14, 1989 VANCOUVER DISTRICT OFFICE HEAD OFFICE Office Examination Section Rulings Directorate J. Jerczynski Financial Industries Division   W.C. Harding   (613) 957-3499 Subject:  19(1) Taxability of Government Annuity This is in reply to your memorandum of June 23, 1989 which was referred to our Division for reply. ...

1 November 1990 Administrative Letter 90M11346 F- Estate Freezes where Discretionary Trust Unedited CRA Tags 245(2), 245(3), 74.1(2), 74.3(1), 74.4(2), 75(2), 86(2) CTF- 1990 Conference Report QUESTION I 96 Estate Freezes Consider the following estate freeze situation where a discretionary trust is used: 1.      ... A, the sole shareholder of Opco, exchanges all of his common shares of Opco, in a transaction to which section 86 of the Income Tax Act applies, for preferred shares of Opco having a fair market value equal to the fair market value of the common shares of Opco. 2.      ... A and his children are the beneficiaries, then subscribes for all of the common shares of Opco. 3.      ...

11 February 1991 Administrative Letter 903666 F- Share for Share Exchange Unedited CRA Tags 85.1, 85.1(1), 85.1(2)(d) Dear Sirs: Re:  Section 85.1 of the Income Tax Act (Canada) (the "Act" We are writing in response to your letter of December 18, 1990 wherein you requested our comments on the following hypothetical situation. 1.     Taxpayer A enters into an agreement with Xco, a Canadian corporation, whereby A agrees to exchange shares of another corporation for preferred shares of Xco. 2.     The above exchange meets all the conditions described in subsection 85.1(1) of the Act. 3.      ...

14 August 1990 Administrative Letter 901266 F- Worker's Compensation Payments Unedited CRA Tags n/a   August 14, 1990 Source Deductions Division Business and General Mr. ... Jones 957-2104   901266   EACC9317 SUBJECT: Worker's Compensation Payments This is in reply to your memorandum of June 13, 1990 concerning payments made by an employer to an employee pursuant to an agreement between the employer and a Worker's Compensation Board to provide vocational or on-the job training for an injured employee. ...

6 December 1990 Administrative Letter 902636 F- Rollover of Assets Followed by Immediate Sale of Assets Unedited CRA Tags 85(1)   File 902636 1990 Round Table QUESTION A3 Income or Capital Gain: Rollover of Assets Followed by Immediate Sale of Assets With respect to income/capital determinations, what is Revenue Canada's present policy where: (a)     An individual rolls a capital asset with an accrued gain to a corporation which he controls and the corporation sells the asset and realizes the gain soon after the rollover? (b)     A parent corporation rolls a capital asset with an accrued gain to a controlled subsidiary corporation and the subsidiary sells the asset and realizes the gain soon after the rollover? ...

1 August 1990 Administrative Letter EACC9226 F- 1990 T4RSP and T4RIF Guides for Reporting Amounts from RRSPs and RRIFs Unedited CRA Tags n/a   August 1, 1990 Enquiries and Taxpayer Technical Publications Assistance Division Division P. McNally Technical Review Section Director Mary Evans   (613) 957-9229 Attention:  R. ... Bernhard BuetowChiefTechnical Review SectionTechnical Publications DivisionLegislative Affairs Directorate ME/hm(8) COR "C" Enclosures Rec'd July 27/90   7-90695 Memo to Bernhard BuetowChief Technical Review Section I am attaching a copy of the type set guide for reporting amounts from RRSP's and RRIF's.  ...

The Act as a whole is to be read in its entire context so as to ascertain the intention of Parliament (the law as expressly or impliedly enacted by the words), the object of the Act (the ends sought to be achieved), and the scheme of the Act (the relation between the individual provisions of the Act). 2.      ... If the words are apparently obscure or ambiguous, then a meaning that best accords with the intention of Parliament, the object of the Act and the scheme of the Act, but one that the words are reasonably capable of bearing, is to be given to them. 4.      ... However, based on the intention expressed by the Department of Finance and the application of the modern principle of statutory construction, it is our opinion that the words of the Exception: 1)     do not support the alternative interpretation suggested by the taxpayer's representative or by Appeals Division; 2)     can not be interpreted to provide an exception for this particular fact situation; and 3)     must be interpreted to require that the shares be acquired by the taxpayer, i.e., the Estate, after 1971 in an arm's length transaction. ...

11 September 1989 Administrative Letter 58456 F- Transfer of License Unedited CRA Tags 212(1)(d)(i) 19(1) File No. 5-8456   S. Leung   (613) 957-2116 September 11, 1989 Dear Sirs: Re:  Transfer of License Subparagraph 212(1)(d)(i) of the Income Tax Act (the "Act") This is in reply to your letter of July 31, 1989 wherein you requested our confirmation that the above-captioned subparagraph of the Act would not apply to the cost of a license allocated to the Canadian subsidiary in the following hypothetical fact situation. 1)     A U.S. company ("U.S. purchaser") acquires operating assets from an arm's length U.S. vendor.  As part of the asset purchase, the U.S. purchaser pays $10 million for a license to use the trade name, trademarks, logos, etc. of the U.S. vendor for a period of two years. 2)     The U.S. purchaser consequently becomes a licensee under the license. 3)     All foreign and domestic subsidiaries of the U.S. purchaser will exploit the license. 4)     The U.S. purchaser allocates the $10 million cost to each of its subsidiaries, which in turn pays that allocated amount to the U.S. purchaser. ...