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23 June 1989 Administrative Letter 58226 F- Refundable Divided Tax on Hand of a Canadian-controlled Private Corporation Unedited CRA Tags 84(3)(b), 89(1) paid-up capital, 89(1) private corporation, 125(7) Canadian-controlled private corporation, 129, 186 19(1) File No. 5-8226   S. Shinerock   (613) 957-2108 June 23, 1989 Dear Sirs: Re:  Subsection 129(1) and 186(1) of the Income Tax Act (the "Act") We refer to your letter of November 10, 1988 in which you requested a technical interpretation of the provisions of subsection 129(1) of the Act as it interacts with the provisions of subsection 186(1) of the Act in the situation described below. ... Paragraph 129(1)(a) of the Act states that:      Where a corporation was, at the end of any taxation year, a private corporation and a return of its income for the year has been made within 3 years from the end of the year, the Minister (a)     may, upon mailing the notice of assessment for the year, refund without application therefor an amount (in this Act referred to as its "dividend refund" for the year) equal to the lesser of (i)     1/4 of all taxable dividends paid by it in the year on shares of its capital stock; and (ii)     its refundable dividend tax on hand at the end of the year. ...

27 March 1992 Administrative Letter 9208706 F- Non-Resident- Foreign Exchange Gain Or Loss Unedited CRA Tags 115(1)(b), 39(2)   920870   O. Laurikainen   957-2116 March 27, 1992 J. GauvreauA/DirectorForeign SectionManufacturing Industries, Reorganizations and Partnerships and Trusts DivisionForeign Division Taxation of Foreign Exchange Gains of Non-residents This is with regard to your enquiry whether a non-resident is taxable in Canada on a foreign exchange gain arising on the settlement of a liability denominated in a currency of a country other than Canada.  ...

You have asked us to review the EIA and to comment on the following issues: a)     whether the costs of setting up plans under the EIA would be deductible under paragraph 20(1)(e) of the Income Tax Act (Canada) (the "ITA"); b)     whether provincial reimbursement of plan set-up costs would be an employee benefit under paragraph 6(1)(a) of the Act or an inducement payment under paragraph 12(1)(x) of the Act; c)     whether shares issued in accordance with the plans would be "short-term preferred shares" or "taxable preferred shares" as those teas are defined in subsection 248(1) of the ITA; d)     whether the depository acting as custodian of shares issued under the plans will be a trustee of those shares for purposes of section 104 of the ITA; e)     whether an employee will be able to deduct interest expense incurred on money borrowed to purchase shares issued under the plans; f)     the nature for tax purposes of any repayment of tax credits made on the early disposition of shares issued under the plan; g)     whether shares issued under the plans will cease to be qualified investments for RRSP's and RRIF's if part of the dividends paid on the shares are in lieu of salary; and h)     whether employees entitled to tax credits in respect of shares issued under the plans would be eligible for a reduced rate of source deductions under subsection 153(1.1) of the ITA. 19(1) has requested that we comment on the following additional issues: i)     whether a deeming provision contained in paragraph 1(2)(c) of the EIA applies for purposes of the ITA; j)      whether an EVCC qualifies to make an election under subsection 39(4) of the ITA; k)     the applicability of subsection 15(1) of the ITA to rights to acquire shares under a plan; and l)     whether the investment protection account established pursuant to section 23 of the is a trust. ... The EIA requires that the retraction price for the share reflect the value of the share, which value may be determined by: a)     an independent opinion from a qualified person; b)     a formula referencing financial information of the corporation; or c)     a formula referencing the trading value of a class of shares of the corporation trading on a public stock exchange; provided that the valuation method d)     applies consistently over the life of the plan; e)     does not provide for a premium for control or discount of minority interests; and f)     is computed without reference to any tax credit provided under the ITA or the Income Tax Act of British Columbia. ... Effect of Paragraph 1(2)(c) of EIA for Income Tax Purposes Paragraph 1(2)(c) of the EIA provides as follows: (2)        For the purposes of this Act (...) ...

McMechan   (613) 957-3499   7-921351 Direct Written Business of a U.K. ... The Queen [1984] CTC 141 (F.C.T.D.), appeal dismissed [1986] 1 CTC 388 (F.C.A.), per Addy, J, at p. 150, that:      "The concept of what constitutes engaging in the business of insurance in Canada is much broader under Canadian insurance legislation than under the laws governing insurance liability. ... "Insurance policy in Canada" is defined in subsection 2405(3) of the Regulations to mean, in the case of: "(a)     a life insurance policy, a life insurance policy in Canada, (b)     a fire insurance policy, a policy issued or effected upon property situated in Canada, and (c)     any other class of insurance policy, a policy where the risks covered by the policy were ordinarily within Canada at the time the policy was issued or effected. ...

Head Office   Financial Industries Division Attention:  Stan Gingrich  G. Kauppinen   (613) 957-2117   File No. 7-4086 Subject:  24(1) This is in reply to your memorandum dated June 12, 1989 wherein you requested our opinion on the following matters: Background 24(1) 23 Comments 1.      ... Presumably, we would tax the trust each year if all waivers were not obtained. 3.     21(1)(b) 4.     23 Position 23 You have also requested our opinion with respect to the following specific questions: Question 1 24(1) Question 2 Does a normal "agency" arrangement constitute an "...other like person... ...

22 February 1990 Administrative Letter F3546 F- Shareholder's Benefit Unedited CRA Tags 15(1)   February 22, 1990 Mr. ... McColm   957-2068   File No. F-3546 Subsection 15(1) The Department of Finance has written, a copy of their letter is attached, asking for an interpretation of subsection 15(1) of the Income Tax Act in a particular fact situation they describe. ...

5 September 1990 Administrative Letter 900846 F- Acquisition of Control on Winding-up Unedited CRA Tags 88(1)(d) 24(1) 900846   M. Vallée   (613) 957-2093   EACC9687 19(1) September 5, 1990 Dear Sirs: Re:  Technical Interpretation Request-  Paragraph 88(1)(d) of the Income Tax Act (the "Act") This is in reply to your letter, dated May 10, 1990, wherein you requested our interpretation of a portion of paragraph 88(1)(d) of the Act in the following hypothetical situation. ...

18 July 1990 Administrative Letter 900916 F- Immigrant's Deductions Unedited CRA Tags 250 19(1) 900916   J.D. Jones   (613) 957-2104   EACC9423 July 18, 1990 Dear Sirs: Re:  Immigrant's Deductions This is in reply to your letter of May 21, 1990, and further to our letter of March 29, 1990, concerning the above noted subject. ...

25 July 1990 Administrative Letter 59746 F- Group Disability Plan Unedited CRA Tags 6(1)(f), 6(1)(a)(i)   24(1) 5-9746   J.D. Jones   (613) 957-2104 Attention: 19(1) July 25, 1990 Dear Sirs: Re:  Paragraph 6(1)(f) of the Income Tax Act (the "Act") Group Disability Plan This is in reply to your letter of March 9, 1990, wherein you requested a technical interpretation of paragraph 6(1)(f) of the Act in the following situation. ...

18 July 1990 Administrative Letter 900816 F- Legal/Accounting Expenses Relative to 21-Year Deemed Realization Rule of Trust Unedited CRA Tags 104(4)(b), 18(1)   July 18, 1990 TORONTO DISTRICT OFFICE Head Office Audit Review Section Rulings Directorate Business Enquiries Group 148 2-1 C. Tremblay   952-1361 G. Cappella   900816   EACC9424 SUBJECT:  Legal and accounting expenses incurred relative to the 21 year deemed disposition rules of a trust This is in reply to your memorandum of May 10, 1990, concerning legal and accounting expenses deducted by the taxpayer Trust during the 1987 and 1988 taxation years.  ...