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Lanzer (613) 957-2129 Dear XXXXXXXXXX: The Honourable Martin Cauchon, Minister of National Revenue, has asked me to reply to your letter of June 2, 1999, addressed to his predecessor, the Honourable Herb Dhaliwal, concerning return of capital. ...

The attributes of the investment vehicle you are contemplating are as follows: 1.      2.      3.     24(1) 4.       5.      ...

Thornley   (613) 957-2101 January 22, 1990 Dear Sirs: Re:  Investment Tax Credit This is in reply to your letter of June 2, 1989 and further to our telephone conversation of November 13, 1989 (Thornley concerning your request for a technical interpretation with respect to subsection 127(10.1) of the Income Tax Act (the "Act"). ...

" 2.      On page 16 of the final draft, the first sentence of the third paragraph under the heading "Employees' stock options" might be clearer if it read as follows:      "Generally the taxable benefit is included in your income in the year you acquire the shares through the option.  ...

In particular, paragraph 2 includes the definition of a retiring allowance while paragraph 3 states that for an amount to be a retiring allowance, the Department, subject to the exceptions in paragraph 4, "accepts cessation of employment for any reason as being retirement... ...

The taxpayers have been resident in Israel for 10 years; 2.     They own shares in a private Canadian holding corporation ("Holdco"); 3.      ...

Interest free loan made by an individual resident in Canada to a related non-resident. 2.      ...

We note that, for purposes of the reduction, the concept of association is not restricted to relationships between corporations but also encompasses relationships between a corporation seeking the tax reduction and a "business", whether or not the business is carried on by a corporation. 2.      ...

Le paragraphe 2 de ce même bulletin précise que le terme "êmettre" signifie mettre en circulation des actions non êmises d'une corporation, que ce soit avec ou sans contrepartie monetaire. ...

Generally, some of the more important criteria which characterize the existence of a joint venture are: 1)     A joint property interest in the subject matter of the venture. 2)     A right of mutual control and management of the enterprise. 3)     A limitation of the objective to a singular or limited number of undertakings. ...