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(d)     A Co and B Co are two arm's-length corporate shareholders of Opco, each of whom owns 50% of the shares of Opco. ... (e)     Can a person be a member of a "group" controlling a corporation if that individual owns no shares of the corporation? ... (d)     If A Co and C Co act in concert to control Opco, they would be considered to be a group of persons that had acquired control of Opco. ...

12 November 1987 Income Tax Severed Letter RCT 5-3701 F Unedited CRA Tags 183.1 Dear Sirs: RE:     Proposed section 183.1 of the Income Tax Act (the "Act") as contained in former Bill C-64 (which received second reading in the House of Commons of Canada on June 30, 1987) This is in reply to your letter of July 30, 1987 in which you requested our opinion on the application of the abovementioned proposed section of the Act to the following hypothetical situation:-     Mr. ... X own all the shares of a corporation ("Opco") which carries on an active business.-     the aggregate fair market value of the shares of Opco is $460,000 while the aggregate paid-up capital of those shares is $20.00.-     as part of an estate freeze Mr. ... X transfer their shares of Opco to a holding company ("Holdco") receiving consideration consisting of preference shares of Holdco which are redeemable at the option of the holder for an aggregate amount of $460,000 and which have an aggregate paid-up capital of $20.00.-     valid elections are filed pursuant to subsection 85(1) of the Act in respect to these transfers.-     as part of the estate freeze common shares of Holdco are issued to Mr. ...

15 September 1988 Income Tax Severed Letter 95-6134 F Dear Sirs: RE:     IT-343R- Meaning of TErm "Corporation" Luxembourg- Societe en Commandite par Actions This is in reply to your letter of May 31, 1988 and further to the additional information received on July 26, 1988. ... Principal Investors Reasons-     Whether societe en commandite par actions in Luxembourg would be considered "corporations" for the purposes of 95(1)(d).-     Yes. ... Pustogorodsky Note: It appears that for determination of interests of investors in a SECPA we must treat interests of Gen Partner & Ltd. ...

16 April 1988 Income Tax Severed Letter A-9637 F Unedited CRA Tags none XXX RE:     Status of West German Entity This is in reply to your letter of March 5, 1984 concerning the above-mentioned subject. ... & Co. KG" is not included in the list in paragraph 3 of the Bulletin (only "G.m.b.H. ... & Co. KG" and are of the opinion that a KG cannot be considered to be a corporation. ...

" Secondly the taxpayer may make a series of designations with respect to items which are considered to be attributable to "... income earned or realized... ... Lastly, any balance of the original dividend should be included in income pursuant to subsection 55(2) of the Act, as it is attributable to something other than "... income earned or realized... ... Various approaches may be taken by the district offices in particular cases to obtain that evidence, such as a requirement that the taxpayer provide for each designation an explanation of the uncertain elements in the calculation of "... income earned or realized... ...

Question 2 What does the reference to "... one of the main purposes... ... Question 3 What is the meaning of the words "... in order to increase the degree of control... ... Question 4 What circumstances or transactions would "... increase the degree of control... ...

8 November 1983 Income Tax Severed Letter RCT 89-086 F Unedited CRA Tags 89(1)(b)(i)(B)(I) RE:     Capital Dividend Account This is in reply to your round-trip memorandum dated October 7, 1983 in which you asked whether a business investment loss is a capital loss that needs to be taken into account under subclause 89(1)(b)(i)(B)(I) in computing the capital dividend account. ... Diguer, Assistant Deputy Minister, Policy & Systems Branch ...

17 February 1987 Income Tax Severed Letter RCT 5-1978 F Unedited CRA Tags 84.1 Dear Sirs: RE:     Section 84.1 of the Income Tax Act (the "Act") This is in reply to your letter of July 29, 1986 in which you requested our interpretation of the words "... was a share substituted for such a share... ... A would be substituted property for the non-voting shares for purposes of determining whether there has been "... a share substituted for such a share... ...

11 June 1985 Income Tax Severed Letter RCT 5-7592 F Unedited CRA Tags 55 Dear Sirs: RE:     Section 55 of the Income Tax Act This is in reply to your letter of April 4, 1985 wherein you requested confirmation of your understanding of the computation of "income earned or realized... after 1971" for the purposes of subsection 55(2) of the Act. ... However, viewing your example in complete isolation, we would agree with the results of your calculation subject to the following:-     losses incurred after 1971 would be deducted in determining the amount of a gain attributable to "safe income"-     dividends received will be included in the "safe income" of the recipient if received out of the "safe income" of a subsidiary. ...

3 October 1980 Income Tax Severed Letter RCT 7-532 F Unedited CRA Tags 85(1), 56(4) RE:     XXX Fractional Shares Received as Consideration for Property Transferred under Subsection 85(1)of the Income Tax Act (the Act) This is in reply to Mr. ... Consequently, an argument can be made (see Alberta & Southern Gas Co. ...