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22 August 1989 Ruling 89M08081 F- General Anti-avoidance Rule- Supplement to IC 88-2 Unedited CRA Tags n/a   DATE   August 22, 1989 TO  Current Amendments and Regulations FROM  Specialty Rulings Division Directorate B. ...

Campbell   (613) 957-2067 November 23, 1989 Dear 19(1) Thank you for your letter of July 12, 1989 with the attached copy of the 24(1)  . ...

10 August 1989 Ruling 74101 F- Publication of Advance Tax Ruling No. 3-2055 Unedited CRA Tags n/a   August 10, 1989 Mr. ...

Brown   957-2082 April 30, 1990 Dear Sirs: This is in response to your letter of January 31, 1990. ...

On XXXXXXXXXX, Acquireco, directly and indirectly, acquired approximately XXXXXXXXXX % of the issued and outstanding common shares of Target pursuant to a take-over bid in consideration for cash. ... The Opco Loan will bear interest at a rate equal to XXXXXXXXXX % which, based on market conditions at the time the loan will be issued, will be considered by Holdco to be a reasonably commercial rate. ... Under XXXXXXXXXX, Opco is precluded from acquiring and holding more than XXXXXXXXXX % of the shares in Holdco for a period exceeding XXXXXXXXXX days. ...

XXXXXXXXXX 2020-085832 XXXXXXXXXX, 2021 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – DC SERP XXXXXXXXXX(the “Taxpayer”) This is in reply to your letter of XXXXXXXXXX requesting an advance income tax ruling (“Ruling”) on behalf of the above-named Taxpayer. ... A Member of the RPP and the Member’s Employer are required to make contributions to the RPP for a calendar year based on the option selected by the Member from the following 3 options: (i) Option 1 – the Member contributes XXXXXXXXXX% of the Member’s Earnings and the Member’s Employer contributes XXXXXXXXXX% of the Member’s Earnings for a total of XXXXXXXXXX% of the Member’s Earnings, (ii) Option 2 – the Member contributes XXXXXXXXXX% of the Member’s Earnings and the Member’s Employer contributes XXXXXXXXXX% of the Member’s Earnings for a total of XXXXXXXXXX% of the Member’s Earnings, and (iii) Option 3 – in the case of a Member who was hired before XXXXXXXXXX (other than a Member who was rehired following termination of employment), the Member and the Member’s Employer contribute the percentage of the Member’s Earnings based upon the Member’s years of Continuous Service specified in the following table: Years of Continuous Member Employer Total Service Contribution Contribution Contribution XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX 6. ... The Taxpayer has also established the two SERPs – that is, the VP SERP and the CEO SERP – which are the subject of this Ruling request. ...

Monsieur X gagne un revenu d'emploi annuel d'approximativement XXXXXXXXXX $ et il est membre de SOCIÉTÉ. 8. ... Monsieur X fera une demande d'adhésion pour un montant de XXXXXXXXXX de XXXXXXXXXX $ avec une option d'âge de 60 ans et il désignera comme bénéficiaire primaire XXXXXXXXXX et comme bénéficiaire secondaire XXXXXXXXXX. Les frais d'adhésion mensuels seront de XXXXXXXXXX $. La date d'entrée en vigueur de l'assurance sera après la date de la présente. ...

Principal Issues: Routine rulings respecting the application & interaction of 118.1(1), (4), (5), (6), 70(5) & Regulation 3501(1.1) Position: Where 118.1(5) applies and a designation is made under 118.1(6) subsection 70(5) shall not apply. Reasons: Subsection 118.1(6) allows taxpayers rep. to designate amount other then FMV. 960446 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1996 Dear Sirs: Re: XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX wherein you requested certain amendments to the advance income tax ruling issued to the above referenced taxpayer January 22, 1996 (file # 951864). ...

As at XXXXXXXXXX, the adjusted equity of Holdco within the meaning of proposed subsection 20.2(2) is $ XXXXXXXXXX which amount is determined as follows: Carrying Value of Property Amount Cash $ XXXXXXXXXX Tax Refund Receivable XXXXXXXXXX XXXXXXXXXX Shares of Opco XXXXXXXXXX Total Carrying Value of Property Liabilities Accounts Payable XXXXXXXXXX Total Liabilities XXXXXXXXXX Profits or Gains on Non-Arm's Length Sales N/A Adjusted Equity $ XXXXXXXXXX 7. ... XXXXXXXXXX Co will use the proceeds from the Public Notes (approximately U.S. $ XXXXXXXXXX) (the "Holdco Loan Amount") to make a XXXXXXXXXX year interest bearing loan to Holdco (the "XXXXXXXXXX Co- Holdco Loan"). ... (c) The maturity date of the Holdco Note will be the XXXXXXXXXX anniversary of the date upon which the Holdco Note is issued (the " Holdco Note Issuance Date"). ...

6 September 1989 Ruling 74273 F- Non-profit Organizations- Revision of IT-83R2 Unedited CRA Tags n/a   September 6, 1989 Roy C. ...