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17 September 1997 External T.I. 9721415- INTERACTION OF SUBSECTION 55(2) & DIVIDEND REFUNDS-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) The fact that a dividend refund has been received by the payor of a dividend is not normally relevant to consideration of the following expression: "that is not refunded as a consequence of the payment of a dividend to a corporation where the payment is part of the series of transactions or events". ...

6 July 1998 External T.I. 9811115- ATTRIBUTION & GENUINE LOAN-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) Discussion of when a loan of money by a parent to a trust will qualify as a "genuine loan" so that s. 75(2) does not apply. ...

8 June 1998 External T.I. 9806285- RRSP- FOREIGN PROPERTY & REINVESTED EARNINGS-- summary under Subsection 206(2) Summary Under Tax Topics- Income Tax Act- Section 206- Subsection 206(2) The cost amount of units of a mutual fund trust that is foreign property include the amount of dividend distributions that have been reinvested in additional units. ...

27 June 1994 External T.I. 9410195- LARGE CORPORATION TAX & CONDITIONAL SALES CONTRACTS-- summary under Subsection 181.2(4) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(4) Where a party (other than a financial institution) acquires a note issued by the purchaser under a conditional sales agreement, the note will be included in the party's investment allowance. ...

7 September 1994 External T.I. 9415545- UNCLAIMED INTEREST & DIVIDENDS-- summary under Subsection 153(4) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(4) The reference to a "taxation year" and "year" in the preamble to s. 153(4) refers to the taxation year of the broker/security dealer and not to that of the unidentified individual (namely, a calendar year). ...

13 October 1994 External T.I. 9413095- CORP.PARTNERSHIPS & PART I.3-- summary under Subsection 181.2(3) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3) Discussion of the application of Part I.3 to loans to and from corporate partnerships, loans between partnerships and the impact of equity-based accounting for partnership interests. ...

30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS-- summary under Subsection 146(4) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(4) An RRSP that writes naked call options would be considered to be carrying on a business. ...

30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS-- summary under Subsection 146(9) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(9) It is the Departmental practice not to apply the provisions of s. 146(9) to an annuitant where an RRSP has written a covered call option and the holder of the covered call option in fact exercises her right to purchase under the option. ...

30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS-- summary under Paragraph 4900(1)(e) Summary Under Tax Topics- Income Tax Regulations- Regulation 4900- Subsection 4900(1)- Paragraph 4900(1)(e) Index options are not qualified investments for an RRSP except in respect of the particular time, if any, when it can be clearly established that cash will be realized if the options are exercised at that time. ...

10 March 1995 External T.I. 9500835- QUALIFIED INVESTMENTS & FOREIGN PROPERTY-- summary under Paragraph 206(1)(h) Summary Under Tax Topics- Income Tax Act- Section 206- Paragraph 206(1)(h) Canadian government bonds denominated in a foreign currency are not foreign property. ...