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Principal Issues: 1)whether 254(a) applies to the purchase by an RCA trust of annuities providing periodic payments for life & a lump sum for guaranteed portion for the spouse of a deceased employee; 2)whether the employer may loan (i.e. it won't be considered a contribution) the amount needed by the RCA trust to make up the difference between the RCA assets and the price of the annuities (loan to be repaid by the amount of refundable tax the refund of which is triggered by the purchase of the annuities); 3)whether the annuities will be considered subject property of the RCA thereby preventing refund of Part XI.3 tax to custodian after final return filed. ...

FAITS Le 12 décembre An 01, un contribuable (le «Contribuable»), résident du Canada, incorpore une société en vertu de la Loi sur les sociétés par actions et souscrit à 10 actions ordinaires pour 10 $ (la «Société»). ...

Reasons: 1) & 2) Routine- see E9700303. XXXXXXXXXX 970029 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1997 Re: Advance Income Tax Ruling XXXXXXXXXX Incentive Compensation Arrangement This is in reply to your letters of XXXXXXXXXX, in which you request an advance income tax ruling on behalf of the above-named taxpayer, and further to our telephone conversations XXXXXXXXXX. ...

Yours truly, for Director Resources, Partnerships & Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch c.c. ...

While the declaration indicates that a member holds the share certificate in trust for the Organization and that the member has no beneficial ownership in the share, the declaration then specifies that the member has transferred the said share certificate in blank, " XXXXXXXXXX" In this respect, the representative further indicates that "the Share Certificate is transferred in blank in favor of the company. ...

The IT states that where this occurs, "... the portion of the lump-sum payment which would have been taxable had it been received by the decedent normally is still regarded as income of the estate or the beneficiary; but if the executor desires, for any reason, to report that amount as income of the employee for the year of death pursuant to subsection 70(2), no objection will be made to that manner of reporting nor any consequential election properly made under 70(2). ...

The term "Indian", as used in the Guidelines, is defined on page 10 of the Guidelines to mean "an Indian as defined for purposes of the Indian Act ". ...

Based on the information submitted (excerpt from the By-laws and XXXXXXXXXX "), it appears that XXXXXXXXXX is dedicated exclusively to the social, cultural and educational development of Indians. ...

Sale at FMV after acquisition would result in no gain. 2.Purpose and use of borrowing is to acquire pref shares of Acquisitionco having a dividend rate > interest rate on borrowing. ...

Reasons: Increase in combined contributions by employee & employer to a limit of 18% of pensionable earnings (as defined in registered pension plan) in actual cash contributions to RPP and in notional employer contributions to unfunded plan does not cause the unfunded plan to become a salary deferral arrangement. ...