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3 October 1996 External T.I. 9628565- RRSP ADMINISTRATION & INVESTMENT MANAGEMENT FEES-- summary under Subsection 146.3(2) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(2) Payment by an annuitant of the fees charged for the management of property of an RRIF would be prohibited by s. 146.3(2)(f) and would result in an inclusion in income of the annuitant equal to the fair market value of the RRIF property. ...

3 October 1996 External T.I. 9631565- FEES FOR RRSP & RPP-- summary under Subsection 146.3(11) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(11) Expenses relating to the administration or management of the property in an RRIF will result in an income inclusion to the annuitant pursuant to s. 146.3(11). ...

10 February 1994 Internal T.I. 9316307 F- Indians — Taxation of Income from Various Sources-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) Discussion of the four tests that are applied by the courts in distinguishing between a contract of service and a contract for services. ...

31 July 1995 External T.I. 9518505- PUSH-DOWN ACCOUNTING & PART I.3-- summary under Subsection 181(3) Summary Under Tax Topics- Income Tax Act- Section 181- Subsection 181(3) Where balance sheet amounts have been written up through the application of push-down accounting as sanctioned by section 1625 of the CICA Handbook, such amounts will be used in the computation of large corporations tax. ...

10 May 2001 Internal T.I. 2001-0065827 F- FINES + PENALTIES- INTÉRETS ET PÉNALITÉS-- summary under Paragraph 18(1)(t) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(t) s. 18(1)(t) enacted for greater certainty CRA noted that Ioegen (96 DTC 1993) found that s. 18(1)(t) was enacted for greater certainty. ...

10 March 1999 External T.I. 9829125- PRICE ADJUSTMENT CLAUSE & 80(2)(G)-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date Although a price adjustment clause may be used for satisfying the requirements of s. 80(2)(g), "an acceptable price adjustment clause should not involve the cancelling of issued shares or the issuing of additional shares". ...

10 March 1999 External T.I. 9829125- PRICE ADJUSTMENT CLAUSE & 80(2)(G)-- summary under Paragraph 80(2)(g) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(2)- Paragraph 80(2)(g) Although a price adjustment clause may be used for satisfying the requirements of s. 80(2)(g), "an acceptable price adjustment clause should not involve the cancelling of issued shares or the issuing of additional shares". ...

8 November 1999 External T.I. 9914135- INTEREST & PENALTY RE MICHIGAN SBT-- summary under Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Business-Income Tax The Michigan single business tax is not an income or profits tax for purposes of s. 126. ...

7 October 2005 APFF Roundtable Q. 13, 2005-0141061C6 F- Purchase of Shares by Subsidiary- Sec. 84.1 & 245-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) S.245(2) generally would not apply where an individual ("X") owning 20% of the shares of Opco disposes of his shares of Opco to a newly-incorporated subsidiary of Opco for cash, provided that cash or near-cash does not constitute a significant portion of Opco assets, Opco continues to carry on its business, and Subco and Opco merge following this transaction. ...

8 February 2012 External T.I. 2011-0425411E5- Change in fiscal period & transitional reserve-- summary under Adjusted Stub Period Accrual Income Summary Under Tax Topics- Income Tax Act- Section 34.2- Subsection 34.2(1)- Adjusted Stub Period Accrual Income a corporation with a June 30 year end and which is a member of a calendar year partnership switches to a calendar year. ...