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The following summarizes the projected cash flows comparing the results of the debt remaining outstanding versus the debt being converted into share capital: Current Refinanced with Situation Preferred Shares ($ 000) ($ 000) XXXXXXXXXX The cash flow projections for XXXXXXXXXX for the same period are equal to its proportionate interest in the Property or, XXXXXXXXXX%, of the above amounts. ...

The following summarizes the projected cash flows comparing the results of the debt remaining outstanding versus the debt being converted into share capital: Current Refinanced with Situation Preferred Shares ($ 000) ($ 000) XXXXXXXXXX The cash flow projections for XXXXXXXXXX for the same period are equal to its proportionate interest in the Property or, XXXXXXXXXX%, of the above amounts. ...

There are approximately XXXXXXXXXX common shares of Employerco issued and outstanding, which are held as follows: Shareholder # Shares % Held XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX 4. ...

RULINGS DIRECTORATE CORRESPONDENCE SUMMARY Principal Issues: Minor changes to paragraphs 6 & 7 of the "Proposed Transactions" and the addition of wording to Ruling A for the purpose of clarifying the specific taxation year in which the reinsurance premium is to be deducted from and included in income. ... Yours truly, for Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

With respect to certain specific arguments advanced in your letter concerning the conditions specified in paragraph 21 of Interpretation Bulletin IT-268R3, our comments are as follows: 1.      ... In our view, if the property is held for the "exclusive benefit" of a particular child, both the proceeds of any sale and income derived therefrom must be for the exclusive benefit of that child. 2.      ...

As stated in paragraph 1 of Interpretation Bulletin IT-85R2, in order for the Trust to qualify as a health & welfare trust, the benefit programs funded through the Trust must be restricted to one or more of the following plans:          a) a private health services plan (PHSP), b) a group term life insurance policy, or c) a group sickness or accident insurance plan. ...

", whereas subsection 122.4(3) of the Act (FSTC) states that "... the amount... shall be deemed to be an amount paid... on account of... tax under this part... ". As a consequence of this wording the FSTC cannot be included in the computation of the net federal tax payable for instalment purposes. ...

14 July 1989 Ruling 73861 F- Indirect Payments Unedited CRA Tags 56(2)   July 14, 1989 To: Audit Applications Division From: Small Business and J. Daman, A/Director General Division   J.D. Jones W.A. Fulton 957-2104 Chief Application Opinions Section File No. 7-3861 Subject:  Technical Interpretation of Subsection 56(2) of the Income Tax Act (the "Act") This is in reply to your memorandum of April 25, 1989, wherein you requested our views on the Department's policy with respect to the recipient where subsection 56(2) of the Act is being applied in a situation similar to McClurg (88 DTC 6047). ...

Our Comments As stated in paragraph 3 of the Interpretation Bulletin IT-92R2, the holdback must be included in the contractor's income on the day that is the later of: (a)     the day on which the architect or engineer issues the final certificate of job completion, and (b)     the day of expiration of the lien period as stipulated in the applicable provincial statute. ...

On XXXXXXXXXX, Parent transferred legal title to XXXXXXXXXX % of the outstanding shares of Bidco to XXXXXXXXXX 3. ... Managements of Bidco and Profitco have concluded that a reasonable interest rate to be charged on the Profitco Notes would be XXXXXXXXXX %. 19. ... Annually (or more frequently), Newco will pay dividends of $XXXXXXXXXX ($XXXXXXXXXX x XXXXXXXXXX %) to Profitco if the proposed structure is not partially unwound. ...