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Albert, Section 23Question # 42 ...

11 August 1989 Ruling 80313- Appel de décision défavorable Unedited CRA Tags 80   Le 11 août 1989 BUREAU PRINCIPAL BUREAU PRINCIPAL DIRECTION DES APPELS Direction des décisions Division des Appels et Renvois Division des services bilingues M.E. ...

27 April 1990 Ruling 90M04003 F- Remission of Tax Unedited CRA Tags n/a Return signed copy Technical Review Section, Publications Division Room 1016, Cumberland Place   April 27, 1990 19(1) The Honourable Otto Jelinek, Minister of National Revenue, has asked me to reply to your letter of January 26, 1990, addressed to his colleague, the Honourable Robert de Cotret, concerning your request for remission of tax on behalf of 19(1) I apologize for the delay of my response. ...

Campbell   (613) 957-2067 December 19, 1990 Dear:  19(1) We received your most recent letter on your tax status. ...

25 October 1990 Ruling 902341 F- Reciprocal Exchanges Unedited CRA Tags n/a 24(1) 902341   (613) 957-8963 19(1) October 25, 1990 Dear Sirs: This is in reply to your letter dated August 27, 1990 concerning the views expressed by the Department in a letter to another taxpayer dated April 24, 1986. ...

6 December 1990 Ruling 902631 F- General Anti-avoidance Rule on Sale of Shares Unedited CRA Tags 110.6, 245(2), 247(1) arm's length allocation   File 902631 1990 Round Table QUESTION I 28 GAAR- Sale of Shares of Cashco An individual owns all the shares of a corporation ("Cashco") the assets of which are primarily liquid assets. ...

Does the failure to make an offer when there is an Assets Sale over $ XXXXXXXXXX constitutes an acceptable event of default? ... The Existing Term Facility bears interest based on the Canadian banker's acceptance rate, plus a margin, which averaged approximately XXXXXXXXXX % in XXXXXXXXXX. ... ABC Fund will use approximately US $XXXXXXXXXX of the net proceeds to equity finance ABC XXXXXXXXXX and approximately US $ XXXXXXXXXX of the net proceeds to equity finance ABC GP to repay part of its Existing Term Facility. 21. ...

We have previously ruled (9805343) and opined (960628 & 913459) that securities lending arrangements constitute investing of funds in property. See 961004 & 991731 where similar rulings with respect to the consolidation of units were provided. ...

Relevant details concerning these trusts are as follows: Name of trust Trustee * Beneficiaries XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX *All decisions regarding the administration of the trusts must be approved by a majority of the trustees. 5. ... Each share carries a fixed non-cumulative dividend rate of XXXXXXXXXX % per annum.- class A voting preferred shares redeemable and retractable for $XXXXXXXXXX each having a par value of $XXXXXXXXXX each. Each share carries a fixed non-cumulative dividend rate of XXXXXXXXXX % per annum. ...

Reasons FOR POSITION TAKEN: Upon conversion from one class to another the basic difference will be the XXXXXXXXXX however as all rights & privileges of the unitholder have remained the same with respect to units held before & after reclassification occurs, there is no disposition. ...