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Nos commentaires De façon générale, nous sommes d'opinion qu'un prêt à recevoir inter-compagnie entre corporations liées n'est pas "... un élément d'actif utilisé dans une entreprise que la corporation ou une corporation qui lui est liée exploite activement... ...

28 September 1989 Income Tax Severed Letter AC32558- Taxable Preferred Share- Dividend or Liquidation Entitlement Established to be not Less than Minimum Amount September 28, 1989 Leasing & Financing Section Blair P. ...

Finally, you have suggested that line 32 of form T691(E) "Calculation of Minimum Tax " is misleading. ...

Clark Chief Leasing & Financing Section Financial Industries Division Rulings Directorate ...

XXXX Comments & Observations Paragraph 8(1)(b) states, in part, that "(1) In computing a taxpayer's income for a taxation year from an office or employment, there may be deducted... ...

We also refer to Olympia & York Developments Ltd. v The Queen, 80 DTC 6184 (FCTD), at p. 6193. ...

As stated in paragraph 1 of IT-85R2, in order to qualify as a Health & Welfare Trust, the benefit programs funded through the trust must be restricted to one or more of the following plans: a) a private health services plan, b) a group term life insurance policy, or c) a group sickness or accident insurance plan. ...

Applying these conclusions to XXXX 1988 taxation year, the dividends deemed to have been received by her and consequently reportable by XXXX as dividends in respect of that year would comprise the XXXX monthly its of $ XXXX due and payable from XXXX to inclusive, for a total amount of $XXXX. ...

Our understanding of the scenario set out in your letter is as follows: A father, who is engaged in the business of farming, owns the following property: Farmland- fair market value ("FMV") $435,000 Farmland- Adjusted Cost Base ("ACB") 160,000 Depreciable Property- FMV 349,000 Depreciable Property,- undepreciated Capital Cost (UCC) Class 10 $80,000 Class 8 55,000 Class 6 30 000 $165,000------ Pursuant to subsection 73(3) of the Income Tax Act, the father proposed to sell the farmland and depreciable property to an adult son for the following consideration: Farmland- FMV $435,000 Depreciable Property- UCC 165 000-------- $600.000 ======== The agreement for sale (the "agreement") calls for payments of $60,000 per year for ten years, without interest. ...

The test as to whether separate businesses exist is found in Scales v George Thompson & Company Limited (1927), 13 TC 83. ...