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8 December 1983 Income Tax Severed Letter RRRR86- Foreign affiliate project LA 5601-C3 — interest income Unedited CRA Tags 95(2)(a)(i) We have reconsidered our position, at your request, that was stated in our memorandum of April 11, 1983 to you concerning whether the interest income of XXX pertains or is incident to the active business of a related foreign affiliate and is thereby deemed under the provisions of subparagraph 95(2)(a)(i) of the Act to be active business income. ...

7 October 1991 Income Tax Severed Letter- Conversion of preferred shares — subsection 15(1) benefit Unedited CRA Tags 15(1) PRINCIPAL ISSUE SHEET- QUESTION PAGE 27 FOR THE 1991 CANADIAN TAX FOUNDATION ROUND TABLE Issue In responding to this query it was assumed that at the time the preferred shares were issued, the holder had the option of converting them into common shares at a preset ratio, or they could be redeemed for a preset amount of cash. ...

11 June 1992 Income Tax Severed Letter- Forgiveness of loan interest — farmers Unedited CRA Tags 80(1), 80(4) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

7 May 1991 Income Tax Severed Letter- Foreign affiliates deemed active business income — insurance premiums Unedited CRA Tags 95(2)(a)(ii), Reg. 5907(2)(j) FOREIGN AFFILIATES DEEMED ACTIVE BUSINESS INCOME- INSURANCE PREMIUMS Question Canco is a Canadian corporation that owns 100% of the shares of a foreign affiliate ("FA1") resident in Ireland. ...

7 October 1991 Income Tax Severed Letter- Redeemable, convertible preferred shares — subsection 15(1) benefit Unedited CRA Tags 15(1) REDEEMABLE/CONVERTIBLE PREFERRED SHARES-SUBSECTION 15(1) BENEFIT Question on page 27 A shareholder holds fixed redemption amount preference shares that are convertible into common shares. ...

14 April 1982 Income Tax Severed Letter RRRR83- Non-resident withholding tax exemption — certificates of deposit Unedited CRA Tags 212(1)(b)(iv) XXX This is further to my letter of April 14, 1982 and in reply to your letter of March 10, 1982 concerning the eligibility of Certificates of Deposit for the purposes of the exemption contained in subparagraph 212(1)(b)(iv) of the Income Tax Act (the Act). ...

7 December 1991 Income Tax Severed Letter- Deferred salary leave plan — period of leave of absence Unedited CRA Tags Reg. 6801 Dear XXX Re: Deferred Salary Leave Plan We are writing in reply to your letter of June 7, 1991, to the Kitchener District Taxation Office which was forwarded to us on August 1, 1991. ...

7 March 1991 Income Tax Severed Letter- Leasing transactions — non-resident lessor Unedited CRA Tags none Dear Sirs: Re: Leasing Transactions This is in reply to your letter of January 23, 1991 wherein you requested confirmation that the transaction described in your letter between a Canadian lessee and a non-resident lessor would, although structured as a lease, result in a disposition and acquisition of the property that is the subject of the lease for all purpose of the Income Tax Act (the “Act”). ...

7 May 1991 Income Tax Severed Letter- Capital cost allowance — half year rule on non-arm's length transfers Unedited CRA Tags 85, Reg. 1100(2.2) Question Capital Cost Allowance- Half Year Rule on Non-Arm's Length Transfers A and B are Canadian resident related corporations. ...

18 June 1992 Income Tax Severed Letter- Nikkei index call option — whether qualified investment for registered retirement savings plan Unedited CRA Tags Reg. 4900(1)(e) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...