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This position followed the rationale laid down by the Federal Court of Appeal in Bunge of Canada Ltd. v The Queen [[1984] C.T.C. 284] 84 DTC 6276 where at page 6277 Pratte J stated: "... the equipment required to discharge grain from the appellant's silo was equipment used for `the storing of grain' because the discharge of grain from a silo appears to me to be a necessary and integral part of the storing of the grain... ...

It is your view that, because control of a corporation, as generally defined by the courts for the purposes of the Act, means "... the right of control that rests in ownership of such a number of shares as carries with it the right to a majority of the votes in the election of the Board of Directors... ...

Bernhard Buetow Director Technical Interpretations Division Legislative and Intergovernmental Affairs Branch Document Disclosed Pursuant to the Access to Information Act Document Divulgué en vertu de la loi sur l'accès à l'information LANGIND E DOCNUM ACC8720 REPLACES TYPEKEY R AUTHORDV LEGS AUTHOR SPARNA DESCKEY 6 RATEKEY 1 REFDATE 900115 ETADYEAR ETADSORT ADMINACC LEGS ACCESSLV LEGS99 SUBJECT Draft Revenue Canada charity brochure SECTION none SECTION SECTION SECTION SECTION $$$$ Barbara Darling Director General Registration Directorate S. ...

Since this will result in the conversion of taxable dividends to capital gains in the hands of the Canadian shareholder and since we do not have recourse to a provision such as subsection 84(1) of the Act to remedy the situation, we have brought this to the attention of our Current Amendments & Regulations Division. ...

Read's remarks at the 1988 Tax Conference it is the Department's "... fundamental view that the ability to make a designation under paragraph 55(5)(f) does not relieve the dividend recipient of the onus imposed by the self-assessment system to report as a gain its best estimate of the amount of the dividend in excess of safe income. ...

Paragraph 6202.1(1)(b) Your stated opinion is that "... shares issued pursuant to a flow-through share agreement which contains a termination clause would be flow-through shares as defined by paragraph 66(15)(d.1), notwithstanding that the agreement could terminate prior to the fulfillment of the conditions in that paragraph. ...

SUBJECT: ONTARIO EMPLOYEE WAGE PROTECTION PROGRAM SECTION: 60(j.1), 248(1)- retiring allowance] April 13, 1992 Other Returns & Guides Division Financial Industries Division P. ...

Your questions and comments are as follows: (1) XXX Your company has advised you that a 30% U.S. withholding tax will be deducted from any interest earned by the plan and that an additional 104 penalty will apply as you have not reached the age of 59 & 1/2. ...

This is the only indication in subsection 4602(1) of the Regulations that favours one census year over the other and as such it should be considered as significant when determining whether the 1971 or the 1976 census divisions are to be used. 5) XXX 6) The fact that subparagraphs 4602(1)(h) & (1) of the Regulations refer to census divisions of Northern Saskatchewan and Peace River while the 1971 and 1976 census maps refer only to the division numbers does not appear to be relevant. ...

Through the completion of the Agreement, a Participant will notify the Employer as to the % of his or her current salary to be deferred, the length of time that the Employer will be obligated to reduce his or her salary (the "Deferral Period") and the leave period (the "Leave of Absence"). ...