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17 October 1989 Income Tax Severed Letter ACC8595 F- Source Deduction Tables Unedited CRA Tags n/a 19(1) HBW 8199-2-1   Jim Wilson   (613) 957-2063 October 17, 1989 19(1) In reply to your letter of September 27, 1989, Maurice Corbin of our Source Deductions Division has advised us that the tables are acceptable. ...

The number of days not taxable in this example is calculated as follows: 41 days + (41 days/237 days x 23 days) = 41 + 4 (rounded from 3.98) = 45 days Assume the annual salary was $45,000, the exempt income would be: 45 days/260 days x $45,000 = $7,788. ...

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 that 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 less 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 rates 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 offered to sell shares without regard 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 lover 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 determined 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. ... 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 bid for by Bidder 04 at a rate above the ceiling rate 60 sufficient clearing bids do not existing. ... Acceptance and Rejection of Bids, Bids to Buy end 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 11%, 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 #4 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. ...

In Paragraph 16, the table and the immediately following paragraph are replaced with the following: Asset FMV Dco common shares XXXXXXof the FMV of the Dco shares and advances held by Aco Bco common shares $ XXXXXXXXXX Cco preferred shares $ XXXXXXXXXX XXXXXXXXXX $XXXXXXXXXX XXXXXXXXXX $ XXXXXXXXXX Net current assets XXXXXXXXXX of the FMV For greater certainty, XXXXXXXXXX will be classified as cash or near-cash property for the purposes of this distribution since an agreement has been reached for the sale of this property with a closing date of XXXXXXXXXX. 2. ...

You provided the following example as a not untypical listing of farm assets: $ % Receivables 25,000 3.10 Inventory of feed and livestock 150,000 18.75 Equipment 100,000 12.50 Land 300,000 37.50 House and 1 Acre 100,000 12.50 Barn 125.000 15.65 800.000 100.00 You state that all assets are used in farming for the corporation. ...

In our view, the use of the words "SR & ED... directly undertaken by... the taxpayer" in subparagraph 37(1)(a)(i) in the context of a performer would require that the activities of the performer must qualify as SR & ED in and by themselves. ... Thus, even though the expenditures that are incurred by the contractor in respect of the activities that are performed on his behalf by the performer can be considered SR & ED expenditures of the contractor if they directly support the contractor's SR & ED project, it does not necessarily follow that the performer has carried out SR & ED. ... Thus, a performer that does routine engineering work that directly supports a contractor's SR & ED project would not, in our view, be entitled to the various incentives for SR & ED in respect of the expenditures incurred. ...

However, in Situation 2 a formula for determining the rate of dividend could be as follows: 773 (prime + 3%) = dividend rate.--- 1020 Assuming a prime rate of 20%, the equivalent dividend rate would be 17.43%. a) Prime rate 20.00 Risk premium since 100% of the assets acquired are financed. + 3.00 23.00 Tax 23 x 46% 10.58 Foreign tax credit 23 x 15% = 3.45- 7.13 15.87 Refundable Dividend Tax Taxable income 23.00 10/4 x 3.45 8.63 14.37 x 25% x 2/3 2.40 18.27 Withholding tax 23 x 15% 3.45 Net return on promissory note after tax 14.82 b) Dividend rate 17.43 Withholding tax 15% x 17.43 2.61 Net return on preferred shares after tax 14.82 We would appreciate receiving an opinion at your earliest convenience. ...

Quelques années plus tard, ces actions valent 500 000 $, le solde de l'emprunt étant toujours de 100 000 $. Le prix de base rajusté des actions pour l'individu est de 100 000 $. ... Le montant convenu est de 100 000 $. La compagnie de portefeuille remet en contrepartie des biens acquis un montant comptant de 100 000 $ et des actions ordinaires valant 400 000 $. ...

Social Security Agreement Unedited CRA Tags n/a 19(1) HBW 4131-U3   Al Watson   (613) 957-2072 October 2, 1989 19(1) Your letter of July 4, 1989, and attachments thereto, was referred to this office for review as such extensions require concurrence of the Competent Authorities. ... Savage A/DirectorProvincial and International Relations Division Attachments c.c.      ...

26 September 1989 Income Tax Severed Letter 58211- Paiement des impôts d'une fiducie testamentaire par le bénéficiaire constitue une remise de bien Unedited CRA Tags 104(6)(b), 104(13.1), 104(13.2), 108(1) fiducie testamentaire      5-8211                                                   Ghislain Martineau       (613) 957-8953 Le 26 septembre 1989 Monsieur, La présente est en réponse à votre lettre du 6 juin 1989 dans laquelle vous nous soumettez la situation suivante: Selon les termes régissant une fiducie testamentaire, tous les revenus civils de ladite fiducie sont remis annuellement au bénéficiaire du revenu. l'a fiducie testamentaire se prévaut des articles 104(13.1) et (13.2) de la l'ai de l'impôt sur le revenu (la "l'ai") de sorte que 1e bénéficiaire du revenu n'a pas A inclure dans le calcul de son revenu les montants qui lui ont été payés par la fiducie au cours de l'année.  ...