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Facts The hypothetical facts, as we understand them, are as follows: 1.      ... B owns 100% of all shares issued and outstanding of A. 3.     A's assets consist of cash and non-depreciable capital property. 4.      ... A will be wound up into B under subsection 88(1) of the Act. 7.     The assets of A will be transferred to B upon the commencement of the wind up. 8.      ...

Facts 1.     During Period A, Mr. X, a non-resident, owned a Canadian rental property from which he earned gross rental revenues and in respect of the rental of which he incurred operating costs. 2.      ... X's rental activity did not constitute the carrying on of a business in Canada. 3.      ... X was less than his operating expenses in such year. 4.     Mr. X did not elect under subsection 216(1) of the Act to pay tax under Part I of the Act for any taxation year during Period A. 5.      ...

14 May 1990 Ministerial Letter 900568 F- Qualified Investments Unedited CRA Tags ITR 4900(1)(c), 130.1(5) 24(1) File No. 900568   Maureen Shea-DesRosierss   (613) 957-8953 19(1) May 14, 1990 Dear Sirs: Re: Paragraph 4900(1)(c) of the Income Tax Regulations (the "Regulations") This is in reply to your letter of April 24, 1990 concerning the above-mentioned subject. You describe the following situation: 1.     Mr. X owns one partnership unit of, and is a limited partner of, the XYZ Partnership (hereinafter "XYZ"). ... There are 200 issued and outstanding common shares of MIC. 3.     Each limited partner is the annuitant of a separate RRSP and each RRSP owns 1 share of the MIC. ...

2 May 1990 Ministerial Letter 59438 F- Loan by Corporation to Partnership Unedited CRA Tags 15(2) 24(1) File No. 5-9438   M. Eisner   (613) 957-2138 Attention: 19(1) May 2, 1990 Dear Sirs: This is in reply to your hand written memorandum of January 16, 1990 stating your conclusion that where a loan is made by a corporation to a partnership of which the owner of the corporation  is a member, paragraph 15 of Interpretation Bulletin IT-419 confirms that the loan would not be subject to subsection 15(2) of the Income Tax Act. ...

13 August 1990 Ministerial Letter 59718 F- Société en nom collectif Unedited CRA Tags 115(1)(a)(ii), 96(1) 24(1) 5-9718   O. Laurikainen   (613) 957-2129 Attention: 19(1) August 13, 1990 Dear Sirs: Re: Société en Nom Collectif ("SNC") This is in response to your letter of March 9, 1990. ...

29 March 1990 Ministerial Letter 59598 F- Immigrant's Deductions Unedited CRA Tags n/a 19(1) File No. 5-9598   J.D. Jones   (613) 957-2104 March 29, 1990 Dear Sirs: Re: Immigrant's Deductions This is in reply to your letter of February 6, 1990, wherein you requested our comments concerning deductions available to immigrants in the following situation. ...

23 February 1990 Ministerial Letter 59488 F- Donation of Debt Unedited CRA Tags 69(1)(b)(ii) 19(1) File No. 5-9488   G. Thornley   (613) 957-2101 February 23, 1990 Dear Sirs: Re:  Donation of Debt This is in reply to your letter of January 24, 1990 concerning the tax implications of the donation to a charitable organization of outstanding debt by Canadian institutions holding the debt. ...

18 October 1990 Ministerial Letter 902708 F- Structured Settlements Unedited CRA Tags n/a 24(1) 902708   Glen Thornley   (613) 957-2101 19(1) October 18, 1990 Dear Sirs: Re:  Structured Settlements This is in reply to your letter of September 28, 1990 and further to our telephone conversation of October 16, 1990 concerning the assignment of ownership question with respect to structured settlements. ...

21 June 1990 Ministerial Letter 900598 F- Amounts Deemed Receivable by Spouse on Death of Annuitant Unedited CRA Tags 146(8.91), 60(1), 146(1.1) 24(1) File No. 900598   Maureen Shea-DesRosierss   (613) 957-8953 Attention: 19(1) June 21, 1990 Dear Sirs: This is in reply to your letter of April 27, 1990 wherein you requested a technical interpretation concerning the application of subsection 146(8.91) of the Income Tax Act (the "Act"). ...

28 November 1989 Ministerial Letter 58728 F- Tax on Corporate Distributions Unedited CRA Tags 183.1, 248(10) 19(1) File No. 5-8728   A.A. Cameron   (613) 957-2115 November 28, 1989 Dear Sirs: Re: 24(1) We are writing in response to your letter of September 26, 1989 which outlined a matter relating to our letter to you (the "Opinion Letter") of November 25, 1987. ...