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In International Iron & Metal Company Limited v. MNR, [[1972] C.T.C. 242] (72 DTC 6205), a shareholder agreement was not considered relevant to the determination of control. ...

Former IT-436 contains comments in paragraphs 9 & 10 which, although not included in IT-436R due to the introduction of new 5 year time limit restrictions, are still considered relevant in some situations. ...

The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

Saint John Shipbuilding & Dry Dock Co. Ltd. [[1980] C.T.C. 352] (80 DTC 6272 at page 6274). ...

Is the effect of the amendment to paragraph 8l(l)(c) contained in S.C. 1974-75-76 c. 26 to "overturn" the decision of Furness Withy & Co. ...

In these circumstances the 10 Amalco common shares to be received by the Parent corporation would have a cost of $500,010 computed as follows: Cost of Newco share 87(9)(c)(i) 10 $10 Cash + cost amount of other assets $500,010 ACT of Newco share- 87(9)(c)(ii)(A)(11) 10 500.000 $500,010 Since the Parent corporation will own all of the issued shares of the capital stock of Amalco, the fairmarket value of the 10 Amalco common shares to be issued to the Parent corporation will be equal to $1,000,010. ...

Guidelines are given in the CICA Handbook for which level of % shareholdings create a presumption of significant influence or below which level it is presumed that there is not significant influence but these presumptions are subject to rebuttal. ...

More specifically, the reasons for our position are as follows: a) The question posed in the 1980 Round Table made reference to "... a condominium or other residential property located in the United States... held by a Canadian corporation for the occupancy of the corporation shareholder. ...

Regulation 805 contained in Part VIII of the Income Tax Regulations does not apply to exempt the interest paid to the non-resident where the organization's interest income cannot "... be attributed to the business carried on by him in Canada... ...

However, paragraph 6 or Article XI states that "... the person paying the interest, whether he is a resident of a Contracting State or not, has in a State other than that of which he is a resident a permanent establishment... in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment..., then such interest shall be deemed to arise in the State in which the permanent establishment... is situated and not in the State of which the payer is resident". ...