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5 April 1990 Ministerial Correspondence 74814 F- Deferred Compensation Plan Unedited CRA Tags 6(1)(g), 12(4)   April 5, 1990 TO- Source Deductions Division FROM- Financial Industries L. Mancino, Director Division   D.S. Delorey Attention: R. Cousineau 957-3495 Research and Enquiries Section File No. 7-4814 SUBJECT: 24(1) Deferred Compensation Plan (the "Plan") This is in reply to your memorandum of March 16, 1990. ... Our understanding of the situation is as follows: 1.      2.      3.     24(1) 4.      5.     24(1) OUR COMMENTS Our review of the Plan indicates that the requirement in (b) of the coming-into-force provisions of the SDA definition was satisfied such that the deferrals referred to in 5(b) above were appropriate. ...

20 November 1990 Ministerial Correspondence 902764 F- Acquisition of Control Unedited CRA Tags 249(4), 245(2), 111, 256(7)(a)(i), 251(2), 187(4) 24(1) 902764   H. Woolley   (613) 957-8108 19(1) November 20, 1990 Dear Sirs: We are writing in response to your letter dated October 1, 1990 in which you requested our opinion concerning the application of subsections 249(4) and 245(2) of the Income Tax Act (the "Act") to the hypothetical situation described below. We also acknowledge our related telephone conversation of October 11, 1990 19(1) Woolley. 1.      2.     24(1) 3.      4.      5.      24(1) Our Comments The situation outlined in your letter appears to involve actual contemplated transactions and identifiable taxpayers. ...

Jones   957-2104   File No. 7-4544 Subject:  24(1) This is reply to your memorandum of November 27, 1989, wherein you requested our views 24(1)  In support of their position they cite such court cases as Estate of Phaneuf v. ... Justice Dickson of the Supreme Court of Canada made the following statements with regard to the words "in respect of ":      "The words "in respect of" are, in my opinion, words of the widest possible scope. ... Justice Dickson then cited the above-noted passage from Nowegijick and continued on to say:      "I agree with what was said by Evans, J.A. in R. v. ...

Such internal costs could include (a)       full salaries and benefits of employees who work on the plan full time, (b)       the pro-rata share of salaries and benefits of employees who work on the plan part-time, (c)       the full cost of any equipment and supplies purchased or leased solely to help maintain and operate the plan, (d)       the pro-rata cost of any equipment and supplies purchased or leased in part to help maintain and operate the plan, and (e)       that portion of the rent and overhead that is attributable to the employees and equipment operating and maintaining the plan. ... Where the relevant costs are reasonable, our views on the five points raised on page 2 of your letter are as follows: 1.      ... The method (e.g., implicit or explicit) by which the actuary reflects the fact that such costs were considered is immaterial in and of itself. 3.      ...

In addition, paragraph 37(7)(d) provides that references to SR & ED relating to a business include any SR & ED that may lead or facilitate an extension of that business.  There was a guideline issued in 1982 to determine whether a non-performing funder of SR & ED carries on a research business to which the SR & ED could be automatically related. The following is a brief summary of the guideline: •     The funder must be a principal in the new business to be carried on in the year. ...

We recommend that the description of Issues 1 and 2 be replaced with the following:      ISSUE 1 General Anti-avoidance Rule (GAAR)      Will GAAR apply to a series of transactions involving subsection 85(1) transfers and tax-free intercorporate dividends, the purpose of which is to transfer a specific property of one corporation on a tax-free basis to another corporation in order to provide a fund for the provision of the wife of Mr. X (the holder, directly or indirectly, of all the shares of both corporations) after his death?       ... We recommend that the discussion of ISSUE 1 under LAW AND ANALYSIS in your revised version be replaced with the following:      "The transfer of the X Co Property to Z Co for the ultimate benefit of Mrs. ...

17 July 1991 Ministerial Correspondence 911104 F- Qualified Small Business Corporation Share Unedited CRA Tags 186(4)         911104   Glen Thornley   957-2101 July 10, 1991 Dear Sirs: Re: Qualified Small Business Corporation Share (QSBCS) This is in reply to your letter of April 18, 1991 in which you ask that we reconsider our reply of March 28, 1991. ... Yours truly, for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental     Affairs Branch ...

9 February 1990 Ministerial Correspondence 74694 F- Publication of Advance Tax Ruling 3-2141 ("2141") Unedited CRA Tags 55(3)(b)   February 9, 1990 Legislative Affairs Specialty Rulings Directorate Directorate Firoz Ahmed   957-2092 Roy C. ... We suggest it be changed to read as follows:       "The purpose of this transaction is to ensure that the transfer of the Real Property, described in paragraph 5 of this Part, will be exempt from provincial transfer taxes on real property. ... Issue 2 We suggest that the following sentence be added to the end of the first paragraph:       "This ensures that the Real Property will not be indirectly transferred to Holdco X or Holdco Y, which transfer would not be permitted under paragraph 55(3)(b). ...

Opinions Requested 1.     What is the prime metal stage or its equivalent for potash?  ... 2.     Are the loadout facilities and the onsite storage building, at the 24(1) assets used in processing potash to a stage that is not beyond the prime metal stage or its equivalent for the purposes of the subparagraph 127(9)(c)(iv) definition of qualified property?       ... (Underlining added)      The key phrase of this statement for our purposes would appear to be "capable of sale".       ...

19 January 1990 Ministerial Correspondence 90M01414 F- Minister's Correspondence Unedited CRA Tags n/a   January 19, 1990 WINNIPEG TAXATION CENTRE Technical Interpretations Mr. ... Reich, we are forwarding for your review and appropriate action the file of the above-noted taxpayer, namely (a)       the ministerial correspondence material, (b)       the orange folder with the notice of objection material, and (c)       the taxpayer's T1 tax returns and attachments for 1984, 1985 and 1986. 24(1) We find the Department's treatment of the arrears interest and penalty to be inconsistent.  ...