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In the example above, this amount will be 50% of ($100 + $1000), or $550. Under the provisions of section 84.1(1)(b) of the Act, the required reduction in the adjusted cost base of the shares received will be as follows: The lesser of Adjusted cost base of Opco shares $1000 Paid-up capital of Holdco shares $ 550 lesser- $ 550 minus Paid-up capital of Opco 100 ACB reduction $ 450 ACB of Holdco shares as otherwise elected under Section 85 $1000 Less 84.1(1)(b) reduction 450 Revised adjusted cost base of shares of Holdco $ 550 Since the revised adjusted cost base of $550 is equal to the paid-up capital of the Holdco shares, it is your understanding that the taxpayer can have Holdco redeem shares up to the total amount of the paid-up capital, $550 tax free. ... Accordingly, on the redemption, the following tax consequences will arise: Amount paid or deemed to be paid $1500 Less: Paid-up capital 550 Deemed dividend pursuant to subsection 84(3) of the Act $ 950 Proceeds of disposition pursuant to 54(h) ($1500- $950) $ 550 Less: Adjusted cost base 550 Capital Gain $ 0 It is therefore our view that on the redemption of the Holdco's shares Mr. ...

6 June 1989 Income Tax Severed Letter 57366 F- Limitation on Food and Entertainment Expense Unedited CRA Tags 67.1   19(1) File No. 5-7366   J.D. Jones   (613) 957-2104 June 6, 1989 Dear Sirs: Re:  Technical Interpretation Request Section 67.1 of the Income Tax Act (the "Act") This is in reply to your letter of January 6, 1989, wherein you requested a technical interpretation with respect to the above-noted subject.  ...

As requested please find enclosed: • General Tax Guide and Return Individuals Outside Canada • Capital Gains Tax Guide • Rental Income Tax Guide • Child Care Expenses Tax Guide We trust this will be of assistance. ...

Beginning with the first dividend in the sixth year, the dividend is determined using one of three methods undertaken in the following order: 1) Investor negotiation procedure • direct negotiation between the company and the shareholders if that doesn't work... 2) Dealer bid procedure • obtain bids from Investment Dealers • each bid will specify (1) a fixed or floating dividend rate (2) the fee to be paid to the Dealer if its bid is selected (3) the length of the period to be in force • any such bid is an unconditional offer by the Dealer to purchase all shares tendered by holders • company selects a winner, notifies the shareholders of the dividend rate and the dealer name • shareholders not satisfied with the terms can request tht the dealer purchase all or a portion of their shares if a bid isn't selected by the company or none is submitted... 3) Auction procedure • the dividend rate for each quarter is based on orders placed in an auction conducted prior to the commencement of each quarter • the rate established by auction (the ``Established Rate") will be applicable for the next quarter • the maximum rate allowed may be capped, at say Bankers' Acceptance Rate plus 50 basis points or 110% the `AA" Composite Commercial Paper Rate • existing holders submit any of the following orders: (1) "Hold order"- hold without regard to the Established Rate set by auction (2) "Bid order"- specify number to hold provided that the Established Rate for the next quarter is not less than a specified rate (3) "Sell order"- sell without regard to the Established Rate set by auction • if no order is received, a holder is deemed to have submitted a hold order • individuals interested in acquiring shares may submit "bid to buy orders" with the condition that the Established Rate is not les than a rate specified by the potential holder. • bid to buy orders can come from existing holders as well as new investors • sell and bid orders are irrevocable • if all existing shareholders give hold orders, the next quarter's dividend rate is set, at say 50% of Prime Rate (this clause exists to help ensure that the auction procedure works) The auction procedure works as follows: 1)- the established rate will be the lowest rate that clears the market by matching sales and purchases 2)- a maximum rate is set (``ceiling rate") 3)- existing Holders submit hold, bid, bid to buy and sell orders 4)- potential Holders submit bid to buy orders 5)- determine number of shares available for sale which equals total outstanding less hold orders • if none, established rate set at 50% of Prime Rate 6)- determine whether the number of bid to buy orders with dividend rate less that the ceiling rate which does not include bid orders, is equal to or exceeds the number of shares offered to be sold regardless of dividend rate plus the number of bid orders by existing holders at rates higher than the ceiling rate • if yes, sufficient clearing bids exists • if no, considered a failed auction Sufficient Clearing 7)- the Established Rate is the lowest rate specified in the submitted bid orders which, taking into account such rate and all lower rates bid by Existing Holders and Potential Holders, would result in such Existing Holders and Potential Holders owning all available shares 8)- each Existing Holder with a submitted bid order specifying a rate higher than the Established Rate or that offreed to sell shares without rgard to the rate shall sell their shares 9)- each Existing Holder with a submitted bid order specifying a rate lower than the Established Rate shall continue to hold their shares 10)- each Potential Holder with a submitted bid to buy order specifying any rate that is lower than the Established Rate will buy the number of shares so submitted 11)- each Existing Holder with a submitted bid order specifying a rate equal to the Established Rate shall continue to hold their shares unless the number of shares subject to all such submitted bids is greater than the shares available determined in (5) less the number already already allocated in (9) and (10) (``Remaining shares"), in which case each Existing Holder with such a submitted bid shall sell a number of shares detemined on a pro-rata basis: Remaining shares-------------------------- x Bidder's shares involved in tie All shares involved in tie • no pro-rations were required prior to this point due to the condition imposed in (6) above. 12)- each potential holder with a bid to buy order specifying a rate equal to the Established Rate shall purchase any available shares not accounted for in (9), (10), and (11) above on a pro-rata basis: Available shares less (9),(10),(11) x Individual's request to bid to buy---------------------------------- Total # of shares still subject to bid to buy • the operation of an auction is illustrated in attached example 1. ... Example 2- Failed auction "AA" composite Commercial Paper Rate 10% Ceiling is therefore 110% of 10% or 11% 100 shares outstanding #1 10 shares #2 20 shares #3 30 shares #4 30 shares #5 10 shares--- 100 Bid and Sell orders from Existing Holders #1 Sell 10 shares #2 Sell 20 shares #3 Continue to hold 30 shares if new rate at least 9.250% #4 Continue to hold 30 shares if new rate at least 11.300% #5 Continue t hold 10 shares if new rate at least 9.250% Bids to Buy Orders from Potential Holders #6 Buy 20 shares if new rtae is at least 10.125% Available Shares 100- # subject to firm hold = 100- 0 = 100 As the number of bid orders by Potential Holders specifying rates equal to or lower than the ceiling rate 20 shares bid by bidder #6 is less than the number offered to be sold by Existing Holders regardless of the dividend rate plus the number bid by Existing Holders at rates higher than the ceiling rate: 10 shares offered to be sold by Bidder #1 20 shares offered to be sold by Bidder #2 30 shares bi for by Bidder #4 at a rate above the ceiling rate-- 60 sufficient clearing bids to not existing. ... Acceptance and Rejection of Bids, Bids to Buy and Sells 1) Existing Holders with bid rates equal to or lower than 11%, continue to hold Bidder #3 holds 30 shares Bidder #5 holds 10 shares 2) Potential Holders with bid rates equal to or lower than 1%, purchase Bidder #6 purchases 20 shares 3) Existing Holders with bid rates higher than 11% or that offered to sell without regard to the Established Rate, sell a pro-rata number to meet demand Bidder #1 wants to sell 10 shares Bidder #2 wants to sell 20 shares Bidder #3 wants to sell 30 shares but only 20 shares need to be sold Each sells a proportionate number: Bidder $1 sells 10 x 20 = 3-- 60 Bidder #2 sells 20 x 20 = 7-- 60 Bidder #3 sells 30 x 20 = 10-- 60 After settlement, shareholdings are as follows: Bidder #1 holds 7 Bidder #2 holds 13 Bidder #3 holds 30 Bidder #4 holds 20 Bidder #5 holds 10 Bidder #6 holds 20--- 100 Each will receive a dividend of 11.000% for the next quarter. ...

5 August 1993 Income Tax Severed Letter 9310907 F- Large Corporation Tax Mutual Fund Unedited CRA Tags 181.2(3) August 5, 1993 WINNIPEG DISTRICT OFFICE HEAD OFFICE Chief of Audit Rulings Directorate   J.P. ... In exercising professional judgment, established principles for analogous situations dealt with in the Handbook would be taken into account and reference would be made to: (i)     other relevant matters dealt with in the Handbook; (ii)     Accounting Guidelines published by the Accounting Standards Committee; (iii)     Abstracts of Issues Discussed by the CICA Emerging Issues Committee; (iv)     International Accounting Standards published by the International Accounting Standards Committee; (v)     standards published by bodies authorized to establish financial accounting standards in other jurisdictions; (vi)     CICA research studies; and (vii)     other sources of accounting literature such as textbooks and journals. ... In the case at hand, the accounting principles employed; (i)     are generally accepted by virtue of their use in similar circumstances by a significant number of entities in Canada; (ii)     are consistent with the recommendations of the above referenced Research Study; and, (iii)     are consistent with the recommendations in the aforementioned exposure draft. ...

Your example is as follows: Amount of loan (proceeds of disposition per subparagraph 148(9)(e.2)(ii) of the Act) $3,000 ACB of life insurance policy (paragraph 148(9)(a) of the Act) 2,600------- Income of policy holder (subsection 148(1) of the Act) $ 400 ====== The repayment of the policy loan three years after the loan was taken out results in the following: (a) A deduction in computing income will be allowed for $400 of the $3,000 repaid under paragraph 20(l)(hh) of the Act. ... (paragraph 148(9)(a)(ii)) $2,600 Amount previously included in income (paragraph 148(9)(a)(iii)) 400 Amount repaid ($3,000) less amount deductible under paragraph 20(1)(hh) ($400) (paragraph 148(9)(a)(iv)) 2,600------ 5,600 less: ====== Amount of policy loan previously received (paragraph 148(9)(a)(vi)) 3,000------ ACB of life insurance policy after repayment of loan $2,600 ====== As you can see, the ACB of the life insurance policy after the repayment of the policy loan is the same as it was before the policy loan was taken out. ...

In example: • a Canadian (Manitoba) trust has a sole non-resident beneficiary • the net income of the trust as calculated for non-tax purposes is "payable" to the beneficiary after expenses but before taxes and defines dividends as being income for this purpose. • the beneficiary has a right to demand payment of all income annually.- the trust receives net taxable dividends of $300.00- gross-up available $75.00- tax credit available $50.00- trust expenses $100.00 Therefore: (ignoring other taxes) CASE 1 NO DESIGNATION- trust net income: dividends received $300.00 gross-up 75.00 (expenses) (100.00) sub-total $275.00 less allocation to beneficiary (amount payable) (200.00)- Trust Net Income $75.00- Trust Flat Tax Payable (2%) $ 1.50- Tax Credit (50.00)- Part XIII tax Payable [212(1)(c)] 25% * 200.00 $ 50.00 DIVIDEND TAX CREDIT IS RETAINED BY TRUST AND CAN BE APPLIED TO REDUCE FEDERAL TAX PAYABLE CASE 2 FULL DESIGNATION- trust net income: dividends received $300.00 less designated maximum = amount payable (200.00) Deemed dividends received $100.00 gross-up 25.00 (expenses) (100.00) sub-total $ 25.00 less allocation to beneficiary (amount payable*) (25.00) *not exceeding trust income [104(6)(b)]- Trust Net Income NIL- Trust Tax Payable NIL- Part XIII tax Payable [212](1)(c)] 25% *200.00 $ 50.00 DIVIDEND TAX CREDIT OF $16.67 IS AVAILABLE TO THE TRUST BUT IT HAS NO TAXES FOR IT TO BE APPLIED TO. ...

4 December 1989 Income Tax Severed Letter ACC8955 F- Remission of Tax Unedited CRA Tags n/a   89M12417   December 4, 1989 TORONTO DISTRICT OFFICE Technical Interpretations Mr. ... Parnanzone   (613) 957-9232 SUBJECT: 19(1) In her letter of September 7, 1989 (copy enclosed) to our Minister, 19(1) requests tax remission relief in respect of 1984. ...

6 December 1989 Income Tax Severed Letter ACC8834 F- Mandatory Deductions at Source for Fishermen Unedited CRA Tags 153(1)(g), ITR 105.1   89M12358   December 6, 1989 R.J.L. ... Dath Acting Assistant Deputy Minister Director Legislative and Intergovernmental Business and General Affairs Branch Division   957-2089 Mandatory Deductions at Source for Fishermen You have asked us to review the issue raised in Mr. ...

20 September 1989 Income Tax Severed Letter ACC8692 F- Pension Forms Unedited CRA Tags n/a   19(1) HBW 4125-I-7   David R. Senécal   (613) 957-2074 September 20, 1989 19(1) 24(1) We find this quite unusual as these forms are meant to be used by Canadian payers with respect to amounts paid to taxpayers from Canadian pension funds. 24(1) It is therefore difficult to understand on what basis these forms were issued and if the amounts reported related to the same or a different pension plan.  ...