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15 August 1990 Ministerial Letter 59318 F- Meaning of "Corporation" Unedited CRA Tags 95(1) foreign affiliate, 248 24(1) 5-9318   O. Laurikainen   (613) 957-2129 Attention: 19(1) August 15, 1990 Dear Sirs: Re:  Meaning of "Corporation" This is in reply to your letter of December 18, 1989. ...

2 January 1990 Ministerial Letter 32548 F- Distressed Term Preferred Shares Unedited CRA Tags n/a 19(1) File No. 3-2548   Peter Lee   (613) 957-2745 January 2, 1990 Dear Sir: Re:  24(1) Tax Ruling Request Distressed Term Preferred Shares We are writing to confirm your request to withdraw the tax ruling request of July 7, 1989 with respect to a proposed issue of distressed term preferred shares. 24(1) As we are unable to proceed with our review until your client's intentions are confirmed, we are closing our file on this matter. ...

18 January 1990 Ministerial Letter 59338 F- Taxation of Strike Pay Unedited CRA Tags 3(a) 19(1) File No. 5-9338   G. Ozols   (613) 957-2139 January 18, 1990 Dear Sirs: Re:  Taxation of Strike Pay This is in reply to your letter of December 29, 1989 concerning the recent decision of the Federal Court of Appeal on "strike pay" in Her Majesty v. ...

26 September 1989 Ministerial Letter 89M09528 F- Remission Request Unedited CRA Tags n/a   September 26, 1989 Legal Services- Taxation Technical Interpretations   Division Mr. ... Thompson   957-9227 Subject: REMISSION REQUEST 19(1) The documents attached to your memorandum of September 21, 1989 concerning the above-noted case reflect the decision of the Remission Committee with the possible exception of the wording of the condition in the draft order and Explanatory Note. 19(1) 23 R.E. ...

16 November 1989 Ministerial Letter 58928 F- Transfer of Retiring Allowances Unedited CRA Tags 60(j.1) 19(1) File No. 5-8928   D.S. Delorey   (613) 957-3495 November 16, 1989 Dear Sirs: Re:  Subsection 60(j.1) of the Income Tax Act (the "Act") This is in reply to your letter of October 13, 1989 concerning the application of subsection 60(j.1) of the Act in the following hypothetical situation: 1.      ... After 2 years of employment with Corporation B, Corporation B's parent acquires control of Corporation A. 3.      ...

19 December 1990 Ministerial Letter 902918 F- Shares Issued to Avoid Tax Unedited CRA Tags 95(6), 93(4), 5905(8) 24(1) 902918   O. Laurikainen   (613) 957-2129 19(1) December 19, 1990 Dear Sirs: Re:  Subsection 95(6) of the Income Tax Act (the "Act") This is in response to your letter of October 18, 1990 wherein you requested clarification of the application of subsection 95(6) of the Act in the context of the following fact situation. 1.     Corporation A is a taxable Canadian corporation. 2.     Corporation B is a non-resident corporation which is not a foreign affiliate of corporation A nor is it controlled, directly or indirectly in any manner whatever, by corporation A or by a related group of which corporation A is a member. 3.      ...

12 July 1989 Ministerial Letter 74058 F- Employee Savings and Share Purchase Plan Unedited CRA Tags 5(1), 7, 9, 67, 104, 105, 106, 107, 108, 248(1) employee benefit plan, 248(1) retirement compensation arrangement 19(1) File No. 7-4058   F. Francis   (613) 957-3496 July 12, 1989 Dear Sirs: Re:  24(1) Employee Savings & Share Purchase Plan (the ""Plan") This is in reply to your letter of March 27, 1989, to our Registration Division wherein you requested our opinion in respect of proposed amendments to the P;an which will be effective on July 1, 1989. ...

2 February 1990 Ministerial Letter 00258 F- Employment Benefits Unedited CRA Tags 62, 6(1)(b)   February 2, 1990 To- File From- A. Humenuk   957-2135   File No. 0-0258 Subject:  Employment Benefits We have reviewed the attached memorandum of December 19, 1988, from Michael 1.  ...

17 December 1990 Ministerial Letter 901278 F- Voluntary Payments of Interest on Loans Unedited CRA Tags 80.4, 20(1)(c) 24(1) 901278   A. Humenuk   (613) 957-2135 19(1) December 17, 1990 Dear Sirs: Re:  Section 80.4 of the Income Tax Act (the "Act") This is in reply to your letter of June 11, 1990, wherein you requested our views on whether voluntary payments of interest would be considered to be interest paid for the year on a loan which bears no interest or bears interest at a rate lower than the prescribed rate for purposes of paragraphs 80.4(1)(c) and 80.4(2)(e) of the Act. ... However, the Department is still prepared to accept that a timely voluntary payment by an employee to his employer is interest for the purpose of the calculation under section 80.4 provided that: a)     the employer reports the payment as interest income, b)     there is an actual payment by the employee, that is, no journal transfer or exchange of cheques, and c)     the other conditions of section 80.4 are met. ...

Situation I (a)     Mr. A and Mrs. A are married; (b)     In 1975, Mr. ... Situation II (a)     Mr. A and Mrs. A. are married; (b)     In 1975, Mr. ... A's name; (e)     In 1989, the ownership of the two properties was changed back to joint tenancy; and (f)     Subsection 73(1) applied to each of the properties. ...