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The aggregate fair market value of these shares is $5,000,000. 4.      ... The shareholders of Opco wish to creditor-proof this real estate. 5.      ... Holdco will at all times hold all of the issued and outstanding shares of Newco. 7.      ...

Vous nous soumettez les faits suivants: FAITS 24(1) QUESTIONS 24(1) COMMENTAIRES 7.       ... Cependant, nous émettrons les commentaires suivants qui sont d'ordre général et peuvent ne pas être appropriés à votre situation. 8.       ... Aux fins de l'impôt sur le revenu, l'expression "gagner un revenu" signifie faire un profit en louant un bien.        ...

(ii)      payment of the obligation is guaranteed by a non-resident.       ... However, in cases where a guarantee is a separate property it would not, generally, be a qualified investment for an RRSP, DPSP or RRIF.        ... The obligation and rights in respect of the guarantee insurance would not be separately tradeable.       ...

5 April 1990 Administrative Letter 74816 F- German Pension Unedited CRA Tags 56(1)(a)(i), 81(1)(g), 60(a)   DATE  April 5, 1990 TO  International Audits Division FROM  Financial Industries J.A. Calderwood, Director Division   D.S. Delorey Attention: L.W. Mulligan 957-3495   File No. 7-4816 SUBJECT:  19(1) German Pension This is in reply to your handwritten noted dated March 21, 1990 concerning the above-referenced matter. Our understanding of the situation is that (a)      (b)      (c)     24(1) (d)      (e)      The sole issue on which you seek our views is whether the Department should tax only income portion of the pension payments. ...

8 January 1990 Administrative Letter 90M01286 F- Appeal of Adverse Decision Unedited CRA Tags n/a   January 8, 1990 Appeals Branch Technical Interpretations   Division L. ... Fontaine Acting Director 957-9228 Appeals & Referrals Division Subject: 24(1) v MNR Tax Court of Canada We have considered the Reasons for Judgment in respect of the above-noted case heard on November 7, 1989 and it is our view that the adverse decision should be appealed for the following reasons: 1.      2.      3.     24(1) 4.      ...

He to whom a lease is made,      a "tenant" as one who holds lands or tenements by any kind of right. One who has use and occupation of real property of a landlord... the terms of this tenancy being fixed by a "lease", and      "rent" as consideration paid for use or occupation of any property, land, buildings, equipment, etc.            ... The dictionary defines "facilities", among other things, as:-     equipment or physical means for doing something,-     something that is built or installed... to serve a particular purpose.       ...

16 January 1990 Administrative Letter 74436 F- Debtor's Gain on Settlement of Debts Unedited CRA Tags 80(1)   January 16, 1990 Hamilton District Office Specialty Rulings Chief of Audit  Directorate   P. ... (our emphasis)      whereas the reference found in the commercial publication which you consulted stated in part that:      (6)  "For the purposes of subsection (3) and of subsection 24(3), a document evidencing indebtedness to a person to whom shares are to be issued...does not constitute property." (our emphasis)      It is clear that by exchanging the incorrect word, "to" for the correct word, "of", the provision acquires an entirely different meaning.      24(1)      For purposes of subsection 80(1), the "amount paid" would be the fair market value of the shares issued, the "principal amount" would be expressed in CDN $ at the prevailing exchange rate and the "amount for which the obligation was issued" would be expressed in CDN $ at the historical exchange rate.  ...

Bernhard BuetowChiefTechnical Review SectionPublications DivisionLegislative and Intergovernmental Affairs Branch   Appendix   G. Donell   957-9231 1.     SOS.1 "Medical Expenses"      As per discussions with Corinne Salvason, we have attached copies of correspondence between Specialty Rulings and the Thunder Bay district office dated October 8, 1986 in support of the response.       ... In consideration of the above comments we advise striking paragraph 3 of The SOS.3 response.       ...

Paragraph 18(1)(a) is discussed in IT-487. €     Section 67 provides that the outlay or expense is deductible to the extent it is reasonable in the circumstances. €     Outlays and expenses are only deductible after the business has commenced. ... Please refer to paragraphs 6 and 7 of IT-364. €     Paragraph 18(1)(b) denies a deduction for capital outlays. ... Such capital outlays would be capitalized and included in the appropriate Class in Schedule II of the Regulations. €     Paragraph 18(1)(h) of the Act denies a deduction for personal or living expenses. €     Subsection 67.1(1) of the Act limits the deduction to 80% respecting the consumption of food or beverages or the enjoyment of entertainment. ...

Francis   (613) 957-3496 October 16, 1989 Dear Sirs: This is in reply to your letter of August 2, 1989 wherein you requested our opinion in respect to the following situation:-      a Canadian resident individual is an income beneficiary of a non-resident testamentary trust-      Under the terms of the trust, the income of the trust is to be accumulated in the trust for 10 fiscal years of the trust.-      On the first day of the eleventh year, the accumulated income is to be paid out to the income beneficiary. The income for the eleventh and subsequent years is to be paid out to him annually thereafter.-      You have obtained an opinion that the accumulated income is not capital of the trust.-      The trust may or may not be subject to tax on the accumulating income. The preferred beneficiary election is not available.-      You have asked us to assume that sections 94, 94.1 and 245 of the Income Tax Act (the "Act") do not apply. ...