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7 September 1990 Income Tax Severed Letter- Tax consequences to the issuer and holder on the exercise by a holder of the exchange right in an exchangeable debenture Unedited CRA Tags 9, 20(1)(f), 51, 54(h), 206.1 Decision Summary Number 90063-3 Originating Section Leasing & Financing Officer T. ...

Read at the 1988 CTF Conference (at page 18:10) we indicated that the distribution of all of one type of property pro rata to all shareholders should be referred to as a "partial double-winged butterfly" and that a distribution of property of one type "... to one or more (but not all) shareholders... ...

Jacques April v MNR [[1982] C.T.C. 2083] 82 DTC 1093 should also be noted: "... a taxpayer who avers the existence of such long-term program must put forward very convincing evidence that the running expenses claimed are part of an organized and systematic program, planned according to the aforementioned criteria for "earning a profit". ...

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

As stated in paragraph 7 of Interpretation Bulletin IT-433 entitled Farming-Use of Cash Method, "... in certain factual circumstances it is considered that farming includes raising fish... ...

Technically, it is our view that an election would not be available to the lessee under subsection 13(7.4) since the amount was not “... received... in respect of... a depreciable property acquired by him...”. ...

7 November 1991 Income Tax Severed Letter- Goods and Services Tax Rebate- Employees and Partners Unedited CRA Tags 6(8), 12(1)(x), 13(7.1)(d), 20(1)(hh), 70(1), 70(2), 253 Subject: Goods and Services Tax Rebate Employees & Partners This is in reply to your memorandum dated July 9, 1991 wherein you requested our opinion concerning the application of several amendments to the Income Tax Act (the "Act") as part of Bill C-62. ...

"... In substance, the term is the space of time during which the debtor cannot be required to make, and the creditor to receive, the payment of the debt. ...

The DNR has made two public comments on the issue: (a) 1980 Conference Report: Q.23 “... shares issued on the incorporation of a wholly-owned subsidiary would not as a rule be in the ordinary course of business.” ...

Paragraph 11 of IT-496, suggests that enabling documents may provide that all of the “... assets and accumulated income are to be transferred to an organization with similar objects that qualifies for exemption pursuant to paragraphs 149(1)(f) or (l) of the Act”. ...