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"Partial Payment Rec'd for GIC & Accrued Interest")-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) "Unless there is any indication to the contrary, payments received in partial payment of debt (in this case, a GIC) should be applied first to interest rather than to principal. ...

15 January 2007 Internal T.I. 2006-0216801I7- Redemption of US $ Denominated Shares-- summary under Subsection 84(3) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(3) MacMillan Bloedel to be followed Confirmation of a previous position that in light of the MacMillan Bloedel decision, CRA intends to assess any redemption of foreign-currency-denominated redeemable and retractable preferred shares on the basis that s. 39(2) applies to the issuer corporation. ...

2006 Ruling 2004-0106101R3- Class of German Arrangement & Treaty Benefits-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Ruling that a German open-end real estate fund would be treated as a resident of Germany for purposes of Article 4 of the German Treaty. ...

7 March 1997 External T.I. 9704665- NASDAQ & OTC BULLETIN BOARD-- summary under Regulation 3201 Summary Under Tax Topics- Income Tax Regulations- Regulation 3201 The Over-the-Counter Bulletin Board market in the United States is not a prescribed stock exchange, notwithstanding the ownership of that market by the National Association of Securities Dealers, Inc. ...

17 September 1997 External T.I. 9721415- INTERACTION OF SUBSECTION 55(2) & DIVIDEND REFUNDS-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) The fact that a dividend refund has been received by the payor of a dividend is not normally relevant to consideration of the following expression: "that is not refunded as a consequence of the payment of a dividend to a corporation where the payment is part of the series of transactions or events". ...

6 July 1998 External T.I. 9811115- ATTRIBUTION & GENUINE LOAN-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) Discussion of when a loan of money by a parent to a trust will qualify as a "genuine loan" so that s. 75(2) does not apply. ...

8 June 1998 External T.I. 9806285- RRSP- FOREIGN PROPERTY & REINVESTED EARNINGS-- summary under Subsection 206(2) Summary Under Tax Topics- Income Tax Act- Section 206- Subsection 206(2) The cost amount of units of a mutual fund trust that is foreign property include the amount of dividend distributions that have been reinvested in additional units. ...

23 March 1994 Administrative Letter 9332416 F- Japan Inhabitant's Tax — Income or Profits Tax-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax The municipal inhabitant's tax imposed by Japan is an income tax with the exception of any per capita tax included in that tax. ...

27 June 1994 External T.I. 9410195- LARGE CORPORATION TAX & CONDITIONAL SALES CONTRACTS-- summary under Subsection 181.2(4) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(4) Where a party (other than a financial institution) acquires a note issued by the purchaser under a conditional sales agreement, the note will be included in the party's investment allowance. ...

14 July 1994 Internal T.I. 9407377- NON-RESIDENT PARTNER & 216 ELECTION (7558-3)-- summary under Subsection 216(1) Summary Under Tax Topics- Income Tax Act- Section 216- Subsection 216(1) Brief discussion of application of s. 216 election where there is a non-resident partner in a partnership receiving rents from a MURB property. ...