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& Mrs. X are married. Pursuant to paragraph 251(2)(a) of the Act Mr. & Mrs. X are related persons. Pursuant to paragraph 251(1)(a) of the Act related persons are deemed not to deal with each other at arm's length. ... & Mrs. X are contemplating getting a divorce is not a relevant issue in determining whether or not they deal with each other at arm's length. ...

MNR [[1974] C.T.C. 209] (supra), is that the expenses are incurred "... in connection with..." or "... incidental to..." the borrowing. XXX. As emphasized by the preamble to subsection 20(1) there must be a clear connection between the amount to be deducted and the source of the borrowing. ... In the years under audit the phrase "... a commission or bonus paid or payable to a person... from whom the money was borrowed... ...

This is reasonable because the transferor's potential gain on those shares becomes the transferee's potential gain. ” (Underlining added) In the situation outlined in your letter, since $499,999 of the capital gain will be crystallized on the transfer of the shares of Opco by Mr. ... A's potential gain immediately before the series of transaction = $400,000 x $500,000-------- $899,999 = $222,222 Our above comments are not rulings and are provided in accordance with the practice referred to in paragraph 21 of Information Circular 70-6R2. ...

Where a taxpayer receives a reimbursement in respect of the cost of a property, the amount received must be included in computing his income for a taxation year from business or property if it was received by the taxpayer in the course of earning income from a person who pays the amount * in the curse of earning income from a business or property, or * in order to achieve a benefit or advantage for himself or for persons with whom he does not deal at arm's length. ...

25 October 1990 Income Tax Severed Letter 900841A F- Pre-funding of Group Term Insurance for Retiring Employees Unedited CRA Tags 18(9)(a)(iii), 18(9)(b)   October 25, 1990 Current Amendments and Rulings Directorate Regulations Division R.D. Weil   (613) 957-2141 Attention: Mr. R. D'Aurelio Director 900841 SUBJECT:  Pre-funding of Group Term Insurance for Retiring Employees Attached is a copy of a recent letter from the 24(1) concerning the tax implications of pre-funding a group term life insurance policy for a retiring employee. ...

15 May 1990 Income Tax Severed Letter 90M05259 F- Tax Shelter- Meaning of Prescribed Benefits Unedited CRA Tags 231(6), 231(7), 237.1(1)   May 15, 1990 Vancouver District Office Conference Questions May 1990 QUESTION #8- PRESCRIBED BENEFITS a)     Assume that the shares issued by a corporation to the public are eligible as qualifying investments for certain registered deferred income plans, i.e. ... b)     If a limited partner of a limited partnership is entitled to exchange his partnership unit for partnership property that has a fair market value equal to the fair market value of the partnership unit at the time of disposition, will the fair market value of the partnership property so distributed be considered a prescribed benefit for the purposes of regulation 231(6) of the Income Tax Regulations? DEPARTMENT'S POSITION a)     Where shares issued by a corporation that are eligible as qualifying investments in RRSP, RRIF and DPSP are contributed to and held in such registered deferred income plans by a taxpayer, those shares will be considered "prescribed property" for the purposes of subsection 231(7) of the Regulations and hence will be excluded from the definition of "tax shelter" in subsection 237.1(1) of the Act. b)     The determination of whether a limited partner's ability to exchange his partnership unit for partnership property that has a fair market value equal to the fair market value of the partnership unit at the time of disposition would have the effect of reducing the impact of any loss he may sustain is a determination that can only be made based on the facts of a particular situation. ...

During the XXXX taxation year, the taxpayer incurred some XXXX in direct labour costs, allocated to the cost of M & P labour. ... These accrued amounts were allocated to the cost of M & P labour on the basis that one shareholder spent XXXX of his time on M & P activities while the other spent XXXX of his time on such activities. ... However, it is the Department's view, as implied in IT 145R, that the purpose of the formula is to arrive at the percentage of income which can be regarded as being derived from M & P activities. ...

Présentement, un droit de 90 $ de l'heure est exigé. Un dépôt de 450 $ doit accompagné la demande de décisions. ...

15 March 1993 Income Tax Severed Letter 930593A F- Indians- Glen Williams Decision Unedited CRA Tags 81(1)(a)   ADM'S OFFICE (3) ADM 920582 RETURN TO RULINGS, ROOM 303, MET. ... For instance it has already been determined that the exemption will apply to:-     employment income for duties performed entirely on a reserve;-     employment income for duties performed entirely off a reserve where the employer resides on a reserve and the Indian lives on the reserve;-     employment income for duties, a substantial amount of which are performed on a reserve and either the employer is located on the reserve, or the Indian lives on the reserve; and,-     unemployment, pension and retiring benefits received in respect of exempt employment income. ...

31 October 1986 Income Tax Severed Letter RCT 6092-5 XXX proper interpretation of the phase "... in contemplation of... ... Problem: • the acquisition of the X Co. shares by Newco is not a transaction of the type detailed in subparagraphs 55(3)(b)(iii) through (viii); and therefore if this acquisition is "... in contemplation of... ... Position: • the transfer of the shares of X Co. to Newco was not considered to be in contemplation of the subsequent butterfly. • the denial in 88(1)(d) of a "bump" in respect of property transferred in the course of a butterfly only applies to property that is transferred directly or indirectly to a shareholder corporation in the course of a butterfly. ...