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Ruling

2 July 1991 Ruling 911323 F - Employee Relocation Assistance

We will answer each question in the order in which they were posed. 1.      ... This position is outlined in Revenue Canada's 1990 Employers Guide to Source Deductions (page 62). 6.      ... However, this has not been extended to cover other personal living expenses such as food. 7.      ...
Ruling

2010 Ruling 2010-0381821R3 - Related Foreign Entity Financing

All of the issued and outstanding interests in GP are owned by ACo (XXXXXXXXXX %) and BCo (XXXXXXXXXX %). 6. ... XXXXXXXXXX For Director International & Trusts Division Income Tax Rulings Directorate ...
Ruling

30 November 1996 Ruling 9706043 - SURRENDER OF INCOME INTEREST

3) Do subsections 56(2) & (4) and 74.1(2) apply? 4) Can subsection 107(2) be utilized on the distribution of the trust property to the capital beneficiaries? Position TAKEN: 1) Yes 2) Yes 3) No 4) Yes Reasons FOR POSITION TAKEN: The release of an income interest in a trust for no consideration and the related tax consequences is commented on in IT-385R2 and has been the subject of various rulings and opinions. 1) IT-385R2, Income Interests and previous rulings 9337153 & 9226153. 2) Position re income interests applies to capital interests 9506285. 3) IT-385R2 and previous rulings 933715, 920536 & 922165. 4) Previous rulings 962997, 920536 & 922165. ... The distribution of the property held by the Trust (the common shares of Holdco) to the capital beneficiaries (Child A, B, C & D), will be subject to the provisions of subsection 107(2) of the Act so that the Trust will be deemed to have disposed of the shares for proceeds of disposition equal to their cost amount to the Trust immediately before that time, and each of the capital beneficiaries will be deemed to have acquired their common shares of Holdco at a cost equal to their proportionate share of that amount. ...
Ruling

1999 Ruling 991706A - XXXXXXXXXX RULING

Reasons: The First Fee payable to the XXXXXXXXXX Partnership will now be based on a straight XXXXXXXXXX % (or more) of the XXXXXXXXXX Expenses instead of being contingent on a XXXXXXXXXX. ... Such fixed fee equal to XXXXXXXXXX % of the XXXXXXXXXX expenses was included in the facts provided in our ruling letter, #983239, at paragraph 11. The second paragraph of ruling G of that letter provided that such XXXXXXXXXX % fee would not be an at-risk amount. ...
Ruling

27 October 1989 Ruling 89M10091 F - IFA Stockholm Conference

Specifically, they were the following. 1.     On page 3 the simultaneous audit program should be clarified.  The United States would appear to be the only partner in such an activity, although industry studies may very well be discussed with others. 2.      ... The NR4s are brought together and the appropriate ones selected form the mass for transmission under the tax convention. 3.      ...
Ruling

30 November 1990 Ruling 902751 F - Effect of Government Loans on Cost of Depreciable Property

Based on the scenario described in that reply we outline our current understanding of the amended situation as follows: 1.     The federal and provincial governments have agreed to provide loans to a taxpayer to finance the acquisition of certain plant buildings, machinery and equipment to be completed by 1994. 2.      ... B.     Whether or not a loan can be considered to be unconditionally repayable depends on a finding of fact and would require an examination of the particular loan agreement and surrounding circumstances. ...
Ruling

2010 Ruling 2009-0351351R3 - Post Butterfly Transactions

DC transferred XXXXXXXXXX % of each of its net cash or near cash, business and investment property to TC2 and received shares of TC2 as consideration. ... At the time the XXXXXXXXXX Split-up Butterfly was completed, DC held XXXXXXXXXX % of the issued and outstanding shares of Subco. The remaining XXXXXXXXXX % of the issued and outstanding shares of Subco were held by Employee2. ...
Ruling

7 April 1993 Ruling 3M05481 F - Financial Difficulty Rulings

Francis Sections: 41, 42, 44 Financial Difficulty Rulings This to advise that the following additional rulings, if requested, are now considered "standard" rulings for financial difficulty rulings: 1.     No amount will be included in the income of DistressCo pursuant to subsections 15(1) and 246(1) of the Act solely by virtue of the fact that interest will not be paid or payable by DistressCo to Newco on the Debt. 2.     Provided that the Debt arose from one or more loans made by the SFI in the course of its money lending business, the Debt reacquired by the SFI will be considered to have been acquired by the SFI in the ordinary course of its business of lending money for purposes of paragraphs 20(1)(l) and 20(1)(p) of the Act. 3.      ...
Ruling

16 October 1989 Ruling 89M10351 F - Remission of Income Tax

16 October 1989 Ruling 89M10351 F- Remission of Income Tax Unedited CRA Tags n/a   October 16, 1989 Saskatoon District Office Technical Interpretations Mr. ... Cochrane Division Director- Taxation Greg Middleton   (613) 957-9230 Re:  Remission of Income Tax 19(1) We are enclosing a copy of the Order In Council No. ... CockellDirectorTechnical Interpretations DivisionLegislative and IntergovernmentalAffairs Branch c.c.      ...
Ruling

24 May 1990 Ruling 90M05001 F - Information Circular 71-14R4

24 May 1990 Ruling 90M05001 F- Information Circular 71-14R4 Unedited CRA Tags n/a   May 24, 1990 Mr. ... However, we do offer the following general observation for your consideration. 1.      ... Attached are two overheads which you may fine useful. 2.     In view of the narrow focus of this circular, you may wish to amalgamate it with IC 75-7R3 entitled "Reassessment of a Return of Income" and add a commentary on taxpayers' appeal rights which are dealt with in IC 80-7. ...

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