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3 October 1996 External T.I. 9628565- RRSP ADMINISTRATION & INVESTMENT MANAGEMENT FEES-- summary under Premium Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(1)- Premium annuitant's payment of management fees was a contribution The payment of investment management fees of an RRSP by the annuitant will be treated (unlike the payment by the annuitant of administration fees) as the payment of a premium to the RRSP. ...

3 October 1996 External T.I. 9628565- RRSP ADMINISTRATION & INVESTMENT MANAGEMENT FEES-- summary under Subsection 146(8) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(8) Where funds inside an RRSP (or RRIF) are used to pay administration fees, no benefit or amount is received by the annuitant as a consequence thereof. ...

3 October 1996 External T.I. 9628565- RRSP ADMINISTRATION & INVESTMENT MANAGEMENT FEES-- summary under Subsection 146.3(2) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(2) Payment by an annuitant of the fees charged for the management of property of an RRIF would be prohibited by s. 146.3(2)(f) and would result in an inclusion in income of the annuitant equal to the fair market value of the RRIF property. ...

3 October 1996 External T.I. 9631565- FEES FOR RRSP & RPP-- summary under Subsection 146.3(11) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(11) Expenses relating to the administration or management of the property in an RRIF will result in an income inclusion to the annuitant pursuant to s. 146.3(11). ...

31 July 1995 External T.I. 9518505- PUSH-DOWN ACCOUNTING & PART I.3-- summary under Subsection 181(3) Summary Under Tax Topics- Income Tax Act- Section 181- Subsection 181(3) Where balance sheet amounts have been written up through the application of push-down accounting as sanctioned by section 1625 of the CICA Handbook, such amounts will be used in the computation of large corporations tax. ...

10 March 1999 External T.I. 9829125- PRICE ADJUSTMENT CLAUSE & 80(2)(G)-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date Although a price adjustment clause may be used for satisfying the requirements of s. 80(2)(g), "an acceptable price adjustment clause should not involve the cancelling of issued shares or the issuing of additional shares". ...

10 March 1999 External T.I. 9829125- PRICE ADJUSTMENT CLAUSE & 80(2)(G)-- summary under Paragraph 80(2)(g) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(2)- Paragraph 80(2)(g) Although a price adjustment clause may be used for satisfying the requirements of s. 80(2)(g), "an acceptable price adjustment clause should not involve the cancelling of issued shares or the issuing of additional shares". ...

8 November 1999 External T.I. 9914135- INTEREST & PENALTY RE MICHIGAN SBT-- summary under Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Business-Income Tax The Michigan single business tax is not an income or profits tax for purposes of s. 126. ...

8 February 2012 External T.I. 2011-0425411E5- Change in fiscal period & transitional reserve-- summary under Adjusted Stub Period Accrual Income Summary Under Tax Topics- Income Tax Act- Section 34.2- Subsection 34.2(1)- Adjusted Stub Period Accrual Income a corporation with a June 30 year end and which is a member of a calendar year partnership switches to a calendar year. ...

2 May 1995 T.I. 951062 (File &- 951174 (C.T.O. "New Trust Seed Money from Financial Institution")-- summary under Financial Institution Summary Under Tax Topics- Income Tax Act- Section 142.2- Subsection 142.2(1)- Financial Institution A new trust that is established with "seed money" contributed by a manager or sponsor that is a financial institution will itself be a financial institution until the time that investors purchase units in the trust, thereby reducing the interest of the manager or sponsor below the 50% threshold. ...