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7 April 1992 Administrative Letter 9209186 F- Repayment Of Return Of Pension Contributions Unedited CRA Tags 147.2(4)(c)     5-920918   P. Spice   957-8953 April 7, 1992 Client Assistance DirectorateFinancial Industries Division Mrs. ...

9 April 1990 Administrative Letter 59766 F- Deferred Salary Leave Plan Unedited CRA Tags 6801(a) 19(1) File No. 5-9766   D.S. ... We suggest that the following comments be made as a 24(1)      "Any such interest paid to a participant under the Plan represents employment income rather than income from property. ... " 3.     The following words should be added at the end of   24(1)      "and the leave of absence must commence immediately after the deferral period. ...

18 July 1989 Administrative Letter 58306 F- Minimum Amount under RRIF- Fair Market Value of Property at Beginning of the Year Unedited CRA Tags 146.3(1) minimum amount 19(1) File No. 5-8306   W.C. Harding   (613) 957-3499 July 18, 1989 This is in reply to your letter of June 26, 1989 wherein you requested our interpretation of the term "Fair Market Value" as it is used in paragraph 146.3(1)(b.1) of the Income Tax Act (the "Act") and whether or not it includes accrued interest on debt obligations and "ex-dividends". "Fair market value" is not defined in the Act but has been defined by the courts as being:      "... the highest price available in an open and unrestricted market between informed, prudent parties, acting at arm's length and under no compulsion to act, expressed in terms of money or money's worth". ...

2 July 1991 Administrative Letter 911596 F- "Remission Order" Regarding Moving Expenses Unedited CRA Tags n/a   911596                                         R.B. Day                                         (613) 957-2136 July 2, l99l      19(1) We are writing in reply to your letter of June 6, l99l, wherein you requested background information on the "remission order" regarding moving expenses, that was reported in a recent article in the Toronto Star newspaper. ...

In your response you have summarized the application of subsection 189(4) of the Act as follows: Subsection 189(4) of the Act provides that, in the case of a share or right to acquire a share which was last acquired before April 22, 1982, the lesser of; (a)      4% plus 1% for each 5 calendar years after 1982, and (b)      the average prescribed rate for the year multiplied by 2/3. shall be used to calculate the interest with respect to such shares. ...

" And from Plan A Leasing v MNR 76 DTC 6159 (FCTD) at 6164:      "In law, the title of the lands and the title to the buildings on such lands can be conveyed separately when parties have made a special contract to do so. ... " However, some doubt has been cast on this view in MNR v Mount Robson Motor Inn Limited 81 DTC 5188 (FCA) at 5190:      "When chattels are physically attached to land they may either retain their identity and remain chattels or become part of the land, in which case they are called fixtures. As fixtures are really part of the land, once attached to the land, they become property of the owner of the land; and this is true, as long as the articles remain attached to the land, whether or not the person who affixed them to the land has retained power to sever and remove them.       ...

3 March 1992 Administrative Letter 9204186 F- Pension Splitting Marriage Breakdown Source Deductions Unedited CRA Tags 56(1)(a)(i), 153(1), 60(c)   920418     R.B. Day   (613) 957-2136 March 3, 1992 Source Deductions DivisionA. BissonnetteDirector     19(1)Pension Splitting on Marriage Breakdown Application of 56(1)(a)(i) and 153(1) We are forwarding, for your consideration and reply, the February 6, 1992, Round-Trip memorandum from Source Deductions Division in the Scarborough District Office and the accompanying letter from the taxpayer's representative dated January 14, 1992. ...

22 October 1990 Administrative Letter 902306 F- Determination of Paid-up Capital Unedited CRA Tags 83(1), 84.1, 89(1) paid-up capital, 183.1, 183.2(1), 186(4)   October 22, 1990 SAINT JOHN DISTRICT OFFICE Rulings Directorate Mr. ... In this regard we offer the following comments: The provisions of section 84.1 of the Act apply when an individual shareholder resident in Canada disposes of his shares of a Canadian corporation (the subject shares) to another corporation (the purchaser corporation) in a non arm's length transaction and following which the subject corporation is connected with the purchaser corporation within the meaning of subsection 186(4) of the Act 24(1) Paragraph 84.1(1)(a) of the Act applies to the determination of the paid-up capital of the 24(1) as follows: (A -  B)  X      C     A A = PUC increase in respect of all shares of the purchaser corporation. B = Greater of: (i)     PUC of subject shares (ii)     ACB of subject shares- as adjusted by paragraphs 84.1(2) (a) and (a.1) C = PUC increase in respect of particular class of shares of the purchaser. ...

22 March 1989 Administrative Letter 74537- Régime de prestations aux employés Unedited CRA Tags n/a   March 22, 1989         BUREAU DE DISTRICT                  BUREAU PRINCIPAL       DE SHERBROOKE                       Section des services       Chef de la vérification                bilingues                                           Vicki Plant                                           (613) 957-4796   FILE 7-4537OBJET: Régime de prestations aux employésLa présente est en réponse à votre note de service du 20 novembre 1989 dans laquelle vous demandez nos commentaires, afin de déterminer s'il y a des incidences fiscales autres que celles delà établies par les contribuables. ...

Passive Income- Partnership and Co-Own Unedited CRA Tags 125   911476   A.Y. ... To illustrate, you have provided us the following hypothetical facts:-      Partnership AB, a Canadian partnership, has two partners, A and B.-      Partners A and B deal with each other at arm's length.-     Pursuant to the partnership agreement partner A receives a minimum return on capital invested prior to the allocation of income or loss of partnership AB to the individual partners. ... Yours truly, for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental     Affairs Branch ...