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19 June 1990 Income Tax Severed Letter 74806A F- IT-110R2- Issuance of T4-A Slips by Charities Unedited CRA Tags n/a   June 19, 1990 Legislative Affairs Directorate Business and General Publications Division Division   J.D. ... Shultis 957-2104 Director   File No. 7-4806 Subject: IT-110R2   We are writing to recommend a revision to paragraph 3 of the above-noted bulletin when the bulletin next comes up for revision.  ...

3 April 1985 Income Tax Severed Letter APR 3 1985 Bilingual Services & Finance Division B. ... Chief Finance & Leasing Section Bilingual Services & Finance Division Corporate Rulings Directorate Legislation Branch ...

It is our view that a share purchase warrant issued by a corporation would not constitute a "... right to receive... shares... " of the capital stock of the corporation for the purposes of subsection 85(1) of the Act. ... In our view, it is not possible to comment upon whether such a share warrant would constitute a "... right to receive... shares... ...

Therefore, the types of property held by Subco 1 for purposes of paragraph 55(3)(b) will consist of business property of $1,200 ($300 + $900) and cash of $300 ($200 + $100). ... Following the butterfly, the property of PC and the property of the shareholder-transferee, both determined on a consolidated basis, will be as follows: Property of PC PC Subco2 Consolidated (50%) Basis Cash................... $ 850 $1,000 $1,850 Current liabilities.... (250) (250) (500) Net cash............... $ 600 $750 $1,350 Business property...... $10,150 $3,000 $13,150 Long-term debt......... nil (1,000) (1,000) Net business property.. $10,150 $2,000 $12,150 Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information Property of Shareholder-Transferee (S-T) S-T Subco1 Consolidated (100%) Basis Cash................... $ 500 $ 250 $ 750 Current liabilities.... nil (600) (600) Net cash............... $ 500 $(350) $ 150 Business property...... nil $1,850 $1,850 Long-term debt......... nil (500) (500) Net business property.. nil $1,350 $1,350 As can be seen, the shareholder-transferee has received its proportionate share of each type of property of PC on a consolidated net equity basis. ... Amount Pro Rata Percentage Received Share difference Cash or near-cash.... $ 7,125 $ 7,125 0.0 Investment........... 625 375 66.67 Business............. 42,250 42,500 0.59 Total................ $50,000 $50,000 Although B Co. has received its approximate share of PC's cash or near-cash property and business property, the butterfly will not meet the requirements of paragraph 55(3)(b) since BCo. has received 66.67 percent ($625- 375 = 250/375) more investment property than its proportionate share of that type of property. ...

7 November 1990 Income Tax Severed Letter- Tax-Exempt Dividend Service System XXX We are writing further to your letter dated September 19, 1990, and attachments thereto, concerning the assignment of a Tax Exempt Dividend Service number hereinafter referred to as “TEDS”, to XXX which fall into the following categories: • Canadian Municipalities and • Foreign Governments or entities. ...

15 June 1988 Income Tax Severed Letter 8660 F- Draft Regulations relating to certified film productions Unedited CRA Tags n/a   June 15, 1988   ACC8660 19(1) This is in reply to your letter of June 15, 1988 concerning the draft Regulations relating to certified film productions.  ...

Tang (613) 957-9299 REQUEST FOR TAX REMISSION 2-0181 19(1) We acknowledge the receipt of your memo of June 13, 1989 concerning a request for tax remission by 19(1) (the "Taxpayer"). 24(1) & 19(1) A. 24(1) & 19(1) B. ...

30 June 1989 Income Tax Severed Letter AC73783- Stripped Bonds June 30, 1989 Policy & Systems Branch Legislation & Intergovernmental J.M. ...

Taxable income $3,000 Tax thereon at 50% $1,500 Less ITC 1,500 Tax payable NIL RITC  $5,500 Safe income on hand would be calculated as follows: Taxable income $3,000 Tax payable NIL 3,000 Net outlay not deducted in computing income: Cost $ 100,000 Proceeds (93,000) $ 7,000 RITC $ (5,500) $1,500 Safe income on hand $1,500 Reconciliation Operating income (assuming no difference in calculation of income for tax and accounting) $ 3,000 Proceeds from sale of asset 93,000 RITC 5,500 $101,500 Cost of asset (100,000) Safe income on hand $ 1,500 The above comments represent our interpretation of the guidelines as they would apply to the examples provided. ...

The question and answer were previously dealt with in opinions given to 24(1) dated December 15, 1988 (file # 5-6653) and to 24(1) dated November 2, 1981 (file # A-5765). Prepared by:John Chan May 25, 1992 # 5-921237 Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...