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20 September 1991 Ministerial Letter 912168 F- Lease-Option Agreement Unedited CRA Tags 16.1(1) Dear Sirs: Re:  Lease-Option Agreement This is in reply to your letter dated August 2, 1991 in which you requested our views on the tax consequences of a disposition of a truck by a corporation where the corporation had previously leased the truck from an arm's length party and had, at the end of the lease, exercised its option to acquire the truck from the lessor. ... Payments on account of Rent Paragraph 10 of IT-233R, in part, states "Where a taxpayer acquires a capital property that is a depreciable property for an amount than is less than its fair market value at that time, and the property is one in respect of which the taxpayer....had before that time been entitled to deduct rent for the use...of the property in computing his income, the taxpayer will, by virtue of subsection 13(5 2), be deemed to have acquired that property for all purposes of the Act, at a cost equal to the lesser of: (a) its fair market value at the time of acquisition determined without reference to any option with respect to the property, and (b) the aggregate of (i)   the purchase price actually paid by the taxpayer, and (ii)  all rent paid or payable with respect to the property... ...

For example, on page 4, paragraph 11, you state that lease costs exclude insurance costs paid within a lease will be different for the benefit determined under paragraph 6(1)(a) and 6(1)(e) of the Act. 2)     General: We suggest that the "definition" only be used where the source of the definition is indicated.  ... Subsection 248(1) of the Act defines the cost amount in terms of the U.C.C. of a prescribed class. 3)     Page 1, General Comments, Paragraph 2:  The reference to "grants an automobile to {a} shareholder" suggests that the corporation is transferring ownership of the vehicle rather than making the vehicle available for use.  We suggest the word "provides" rather than "grants". 4)     Page 2, Definition of Automobile, last part of the definition: A)     We think you should adhere more closely to the wording in the Act and add the phrase "in the course of a business or for the purpose of earning income. ...

to require a deposit upon receipt of a ruling request and 2.   to return all or part of the deposit as determined by the circumstances. ...

SavageA/DirectorProvincial and International Relations Division EEC/jbFile copySequence fileAuthor's copyReading fileAccess to info (2) ...

Jones   (613) 957-2104 February 23, 1990 Dear Sirs: Re: 24(1) Group Life Plan (the "Plan") Distribution of Surplus This is in reply to your letters of November 2, 1989, and February 7, 1990, concerning the above-noted subject which has been referred to this office for reply. ...

Simard   (613) 957-8981 Le 30 novembre 1989 Monsieur, Objet:  Demande de décision anticipée 24(1) La présente fait suite à l'entretien téléphonique (Simard 19(1)  du 2 novembre 1989 relativement à votre demande de décision anticipée du 21 novembre 1988 pour le compte du contribuable mentionné plus haut, par lequel vous exprimez le désir de retirer cette demande.  ...

Our understanding of the facts given to illustrate the issues is as follows: 1.      2.     24(1) 3.                                                             4.     24(1) 5.      ... Therefore, it is our opinion that the reasoning of this case does not directly support your position that an agreement to allocate income for a period during which the retired partner was a partner can not be altered without the consent of all parties. 2.      ... Laferriere (currently under appeal),[1985] 2 CTC 190 (FCTD), Delesalle, Dacen and S. ...

A, an employee and a majority shareholder of the corporation, to purchase a dwelling for his habitation. 2.      ... 2.     How would our response to question 1 be changed if Mrs. A was an employee but not a shareholder of Corporation A or if Mrs. ... A, we are unable to express an opinion as to whether or not the loan in the hypothetical situation described above would be a loan described in subparagraph 15(2)(a)(ii) of the Act. 2.      ...

You noted that the plan, a copy of which you included, appeared to qualify as an Employee Profit Sharing Plan (EPSP) in accordance with section 144 of the Income tax Act (the "Act"), and asked: 1)     Would this plan qualify as an EPSP, and 2)     If it is not an EPSP would the proceeds be taxed as employment income or pension income? ... Please refer to Interpretation Bulletin 280 and Information Circular 77-1R3, para. 59; and 2.       ... However, it is of particular note that paragraph 2 of article 17 provides in part that:      "Only years of service after the effective date of this Plan (October 3, 1977)are taken into account when determining a participants vested interest. ...

Raisons POUR POSITION ADOPTÉE: 923154 ADM'S OFFICE (2) RETURN TO 15TH FLOOR, ALBION TOWER Signé le 23 juin 1997 XXXXXXXXXX Maître, La présente fait suite à votre fac-similé du 23 juin 1997 concernant le programme de réduction d'effectifs du secteur public ou para-public du gouvernement du Québec. ...