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13 March 1990 Ministerial Letter 58898 F- Related Corporations Unedited CRA Tags 251(3), 251(2), 251(1) 19(1) File No. 5-8898   Firoz Ahmed   (613) 957-2092 March 13, 1990 Dear Sirs: Re:  Subsection 251(3) of the Income Tax Act (Canada) (the "Act") This is in response to your letter of October 12, 1989 in which you requested our views as to the interpretation of subsection 251(3) of the Act in the context of the situation described below. Subsection 251(3) provides:      Where two corporations are related to the same corporation  within the meaning of subsection (2), they shall, for the purposes of subsections (1) and (2), be deemed to be related to each other. ...

You seek our opinion with respect to different situations. (1)      Repayment of Government Assistance: A) In your example, on June 1, 1993, an Excise reassessment results in a $100 increase to the 1991 GST liability of a taxpayer.  ... You may wish to consult with Current Amendments in this regard. (2)      Receipt of Government Assistance You ask us to consider a situation where a taxpayer is informed on June 1, 1993, by a GST auditor that previously unclaimed input tax credits of $100 are available in respect of a June 1, 1991 expense. ... Note that under section 296 of the Goods and Services Tax the Minister may take into account any amount unclaimed as an input tax credit, deduction or refund and any overpayment of tax with respect to the reporting period being assessed. (3)      Effect of the GST on Sales Proceeds You ask that we consider the following comments and provide our opinion with respect to the issue. ...

3 August 1989 Ministerial Letter 73918 F- Part Year Residents Unedited CRA Tags 118.91, 114(a), 114(b)   August 3, 1989 TO- Non-Resident Taxation Division FROM- Specialty Rulings   Directorate J. ... Laurikainen   957-2125   File No. 7-3918 SUBJECT:  Application of section 118.91 of the Income Tax Act (the "Act") to part year residents of Canada This is in response to your memorandum of May 15, 1989, wherein you enquired about the definition of the term "year" as it is used in section 118.91 of the Act. ...

5 December 1989 Ministerial Letter 58488 F- Asset-Backed Commercial Paper Unedited CRA Tags n/a   19(1) 19(1) 5-8488   C. Robb   (613) 957-2744 December 5, 1989 Dear Sirs: We are writing in response to your letter of August 3, 1989 in which you gave requested our opinion on the subject of Asset-Backed Commercial Paper. ...

28 September 1989 Ministerial Letter 32558 F- Taxable Preferred Share- Dividend or Liquidation Entitlement Established to be not Less than Minimum Amount Unedited CRA Tags 112(2.2)(b), 248(1) taxable preferred share   September 28, 1989 Memo to File Leasing & Financing Section   Blair P. Dwyer   File No. 3-2558 Subject:- Taxable Preferred Shares ("TaxPS")- Dividend and Liquidation entitlements "established to be not less than a minimum amount"- Entitlement determined solely by reference to the entitlement of a non-TaxPS This memorandum concerns the circumstances in which the dividend or liquidation entitlement of a share will be regarded as being not less than a minimum amount for purposes of clauses (b)(i)(C) and (b)(ii)(C) in the definition "taxable preferred share" in subsection 248(1) of the Income Tax Act (Canada) (the "Act"). ... Rationale re Minimum Dividend Entitlement The taxpayer's representative argued as follows:      Although the (Class A) shares are entitled to a preference of $10,000,000 in dividends, the shares provide no guarantee that the full preferential dividend will be paid. ...

4 October 1989 Ministerial Letter 74278- Contribution versée à un REER du conjoint après le délai de 60 jours de la date du décès Unedited CRA Tags 146(5.1), 249(1)   October 4, 1989 Division des demandes de Division des services renseignements bilingues   Charles Thériault P. McNally 957-8981 Directrice   File No. 7-4278 Objet: Contribution versée à un REER du conjoint après le délai de 60 jours de la date du décès La présente note de service est en réponse à la vôtre du 28 août 1989 concernant les contributions versées au REER du conjoint pour le compte d'un contribuable décédé. ... Ainsi, le juge Addy émettait les commentaires suivants à la page 6380 de son jugement:      "Notwithstanding that both counsel seem to share this view, I am not prepared to hold provision to that effect, a deceased taxpayer is, for taxation purposes, deemed to have a taxation year which ends at the end of the calendar year of his decease and, therefore, at a time when he no longer exists.  ...

Campbell   (613) 957-2067 September 22, 1989 19(1) We have your letter of June 27, 1989, regarding the tax status of the above-noted.  ... While the order confers certain tax relief on various individuals, section 3(3) of the Privileges and Immunities Act, under which the Order was issued states:      "Nothing in any order made under subsection (2) shall exempt a Canadian citizen residing or ordinarily resident in Canada, from liability for any taxes or duties imposed by any law of Canada. ...

24 August 1990 Ministerial Letter 59478 F- Computation of Income from an Active Business of a Foreign Affiliate Unedited CRA Tags 95(2)(a)(ii)   24(1) 24(1) 5-9478   O. Laurikainen   (613) 957-2129 Attention: 19(1) August 24, 1990 Dear Sirs: Re: Subparagraph 95(2)(a)(ii) of the Income Tax Act (the "Act") This is in response to your letter of January 24, 1990.  ...

Opco is a Canadian-controlled private corporation within the meaning assigned by paragraph 125(6)(b) of the Act. 2.      ... Included in such assets is real estate with a fair market value of $2,000,000. 4.      ... A, B and C would respectively receive 62.75%, 25% and 12.5% of the Opco Preferred Shares and the new common shares. 6.      ...

11 August 1989 Ministerial Letter 58198 F- Video Tapes Unedited CRA Tags n/a   August 11, 1989 R.A. ... Bowen   957-2096   File No. 5-8198 Re:  24(1) The attached letter has been prepared in response to queries raised by the 24(1) concerning the income tax treatment of the video tapes in.  ...