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21 November 1991 Administrative Letter 911866 F- Goods and Services Tax Rebate- Employees and Partners Unedited CRA Tags 6(8) Re: Goods and Services Tax Rebate Employees & Partners This is in reply to your memorandum dated July 9, 1991 wherein you requested our opinion concerning the application of several amendments to the Income Tax Act (the "Act") as part of Bill C-62. ...

15 January 1990 Administrative Letter 74486 F- Deemed Dividend on Redemption of Inventory Shares Unedited CRA Tags 4(4), 9(1), 12(1)(j), 54 proceeds of disposition, 82(1)(a), 82(1)(b), 84(3), 112, 121, 186(1), 186(1.1), 186.1   January 15, 1990 Current Amendments and Specialty Rulings Regulations Division Directorate Mr. ... As you point out, the position taken by the Department in the 1984 Revenue Canada Round Table is that the difference between the proceeds of disposition and cost is included in income under subsection 9(1) of the Act and that subsection 4(4) of the Act applies to prevent any deemed dividend arising under subsection 84(3) of the Act on the redemption from also being included in income. 23 Our current position is that, upon a redemption of a share held as inventory rather than as capital property: (a)     the difference between the redemption amount and the paid-up capital of the share is deemed to be a dividend paid to, and received by, the shareholder by virtue of subsection 84(3) of the Act; (b)     unless the corporation elects capital dividend treatment in respect of the deemed dividend pursuant to subsection 83(2) of the Act, the amount of the dividend will be included as business income of the recipient by virtue of paragraphs 82(1)(a) and 12(1)(j) of the Act; (c)     if the shareholder is an individual described in paragraph 82(1)(b) of the Act, an additional amount equal to 1/4 of the deemed dividend will be included in computing the business income of the shareholder by virtue of paragraphs 82(1)(b) and 12(1)(j) of the act and such shareholder will be entitled to a dividend tax credit in respect thereof by virtue of section 121 of the Act; (d)     if the shareholder is a corporation described in subsection 112(1) of the Act, it will be entitled to a deduction under subsection 112(1) in respect of the deemed dividend provided that the dividend is a taxable dividend and the deduction is not prohibited by any of subsections 121(2.1, (2.2) and (2.4) of the Act; (e)     to the extent that the paid-up capital of the share exceeds its cost to the shareholder, the excess will be included as business income of the recipient under subsection 9(1) of the Act; (f)     Part IV tax will be applicable to the deemed dividend to the extent provided for in subsection 186(1) of the Act subject to the limitations and exceptions set out in subsection 186(1.1) and sections 186.1 and 186.2 of the Act; and (g)     the adjustment to proceeds of disposition under paragraph 54(h)(x) of the Act is irrelevant (because that provision is only relevant for the purposes of subdivision c of Division B of Part I of Act) and, as the Act provides no similar adjustment to proceeds of disposition or cost for the purpose of computing the gain or loss of the shareholder in these circumstances, any deemed dividend arising under subsection 84(3) of the Act on the redemption of shares held as inventory cannot affect or result in any loss being realized by the shareholder as a result of the redemption. ...

This remains so even if a proposed plan meets all of the requirements for registration set out in IC 72-13R8. 4.     GAAR is not of relevance at the registration stage but may become relevant in considering what action can be taken in respect of plans that have been registered. 5.      ... It is possible for a taxpayer to seek a writ of certiorari against the Minister in these circumstances. 6.      ...

1 September 1989 Administrative Letter 74246 F- Revision of IT-146R3 Unedited CRA Tags n/a   September 1, 1989 Roy C. ... Leung   957-2116 Attention:  T. Bryant Subject:  Interpretation Bulletin Project Number 1963 Revision of IT-146R3 This memorandum is in response to yours dated August 16, 1989. Our comments on version 5 of the above-noted Project (the "Project") are as follows: 1.      ...

The Annual Adjustment will be determined by the following formula: Value = ((A/2)/B) where A = The average for the last three fiscal years of the amounts determined for each fiscal year by taking XXXXXXXXXX percent (XXXXXXXXXX%) of the sales revenue for a year plus XXXXXXXXXX percent (XXXXXXXXXX%) of the Mean Market Price Earnings Multiple multiplied by the consolidated net income after taxes as reported in the consolidated financial statements of the Company for that year. B = The sum of the issued and outstanding Class XXXXXXXXXX common shares and Class XXXXXXXXXX common shares of the Company (after the stock split described in paragraph 5 above) and the Authorized Units as of the last day of the particular fiscal year. ...

The credit will be available for 1988. 2.     The disability begins in May 1988 and ends in January 1989.  ... You sought our views on the following two examples on the last page of your memorandum: 1.      ... Our opinions are: 1.     The child would qualify if, when the impairment was diagnosed, it was reasonably expected to last for a continuous period of at least 12 months. 2.      ...

1 November 1990 Administrative Letter 90M11346 F- Estate Freezes where Discretionary Trust Unedited CRA Tags 245(2), 245(3), 74.1(2), 74.3(1), 74.4(2), 75(2), 86(2) CTF- 1990 Conference Report QUESTION I 96 Estate Freezes Consider the following estate freeze situation where a discretionary trust is used: 1.      ... A, the sole shareholder of Opco, exchanges all of his common shares of Opco, in a transaction to which section 86 of the Income Tax Act applies, for preferred shares of Opco having a fair market value equal to the fair market value of the common shares of Opco. 2.      ... A and his children are the beneficiaries, then subscribes for all of the common shares of Opco. 3.      ...

6 December 1990 Administrative Letter 902636 F- Rollover of Assets Followed by Immediate Sale of Assets Unedited CRA Tags 85(1)   File 902636 1990 Round Table QUESTION A3 Income or Capital Gain: Rollover of Assets Followed by Immediate Sale of Assets With respect to income/capital determinations, what is Revenue Canada's present policy where: (a)     An individual rolls a capital asset with an accrued gain to a corporation which he controls and the corporation sells the asset and realizes the gain soon after the rollover? (b)     A parent corporation rolls a capital asset with an accrued gain to a controlled subsidiary corporation and the subsidiary sells the asset and realizes the gain soon after the rollover? ...

1 August 1990 Administrative Letter EACC9226 F- 1990 T4RSP and T4RIF Guides for Reporting Amounts from RRSPs and RRIFs Unedited CRA Tags n/a   August 1, 1990 Enquiries and Taxpayer Technical Publications Assistance Division Division P. McNally Technical Review Section Director Mary Evans   (613) 957-9229 Attention:  R. ... Bernhard BuetowChiefTechnical Review SectionTechnical Publications DivisionLegislative Affairs Directorate ME/hm(8) COR "C" Enclosures Rec'd July 27/90   7-90695 Memo to Bernhard BuetowChief Technical Review Section I am attaching a copy of the type set guide for reporting amounts from RRSP's and RRIF's.  ...

30 April 1990 Administrative Letter 59276 F- Qualified Small Business Corporation Share Unedited CRA Tags 55(2), 55(3)(a), 55(5)(f), 69(5), 84, 85(1), 88(1), 89(1) taxable Canadian corporation, 110.6(2.1), 110.6(3), 125(7) Canadian-controlled private corporation, 186(4), 245, 248(1) small business corporation 19(1) File No. 5-9276   S. Shinerock   (613) 957-2108 April 30, 1990 Dear Sirs: Re:  Subsection 55(2) of the Income Tax Act (the "Act") We are writing in response to your letter dated December 14, 1989 in which you asked for our opinion regarding the application of subsection 55(2) and certain other provisions of the Act to the two hypothetical situations described below. ...