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3 May 1989 Ministerial Letter 32328 F- Application for Advance Income Tax Ruling Unedited CRA Tags n/a                                                3-70-28378-10-001                                              3-2328                      19(1)                  J.D. Brooks   May 3, 1989   Dear Sirs:                24(1) Re:     Application for Advance Income Tax Ruling Based on submissions which we have received to date, we are not able to provide a favourable ruling for your client named above. ...

The facts in your particular situation are as follows: Facts 1. 2.                       24(1) 3.      4.      ...

Facts 24(1) 24(1) On the basis of these facts you have asked: 1.     Is the liability payment taxable? 2.     Is it eligible for a direct "roll-over" to an RRSP in the same tax sheltered manner as a pension fund transfer or return of pension contributions? ... That definition reads:      "Retiring allowance".- "retiring allowance" means an amount (other than a superannuation or pension benefit or an amount received as a consequence of the death of an employee) received      (a)  upon or after retirement of a taxpayer from an office or employment in recognition of his long service, or      (b)  in respect of a loss of an office or employment of a taxpayer, whether or not received as, on account or in lieu of payment of, damages or pursuant to an order or judgment of a competent tribunal.       ...

You requested our comments related to the following questions: 1.      ... Given the following facts: a)        During a taxation year, the board of directors passes a resolution that certain cash amounts will be used for the prosecution of SR&ED. b)        The cash is invested on a short term basis until it is actually used. c)        All of the cash is eventually used for SR&ED during the year. d)        The interest income received by the corporation in the taxation year from the investment of the funds exceeds the other revenue of the corporation in the year. e)        All or substantially all of the non-interest income of the corporation for the year is derived from the prosecution of SR&ED.       ... Our Comments Our comments related to the above questions are as follows: 1.      ...

26 September 1989 Ministerial Letter 58688 F- Supplemental Report Unedited CRA Tags n/a 19(1) File No. 5-8688   Allan B. Nelson   (613) 957-8984 September 26, 1989 Dear Sirs: 24(1)   Supplemental Report Enclosed, as requested in your letter of September 14, 1989, is a copy of the Energy Mines and Resources supplemental report, dated May 18, 1989, which was prepared for Revenue Canada, Taxation concerning 24(1) The release of this report to you is with the concurrence of representatives of both the Edmonton District Taxation Office and the Department of Energy Mines and Resources. Yours truly, ChiefResource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate c.c.:       Diana Gibson Edmonton district Office      Don SchellDepartment of EnergyMines and Resources ...

30 November 1989 Ministerial Letter 58658 F- Related Persons and the Association of Corporations Unedited CRA Tags 251(2), 252, 256(1) 19(1) File No. 5-8658   A. Humenuk   (613) 957-2135 November 30, 1989 Dear Sirs: Re:  Subsection 251(2) of the Income Tax Act We are replying to your letter of September 6, 1989, concerning related persons and the association of corporations. ... You have also asked whether certain corporations would be associated within the meaning of subsection 256(1) of the Act in the following hypothetical situation: (1)       Brother 1 and Brother 2 own all the shares of Company A. (2)       Each of Brother 1, Brother 2 and Brother 1's son own 20% of the shares of Company B. (3)       An outsider holds the remaining 40% of the shares of Company B. ...

The corporation is responsible for every aspect of the transportation operation: for example, it has complete control over the following elements: 1)     The ship and its usage; 2)     The nature of the goods to be transported; 3)     The ship's crew.  In this respect, the corporation:  -      can determine the way the ship should be loaded,-      can choose the port agent and stevedores that should be used (the corporation pays for their services);-      can ask for the replacement of the captain if it is not satisfied with his performance; 4)     The place from which the ship will be bunkered and the identity of the supplier, the corporation pays for the bunker; 5)     The place where delivery of the goods is taken; 6)     The destination of the goods; and 7)     The place of taking delivery of the ship at the start of the time charter agreement and the place of redelivery of the ship after the expiration of the charter agreement (within a certain range as determined by the charter agreement). ...

A's habitation.      Whether the dwelling can be said to be used for Mr. ... The legal definition of habitation does not preclude the possibility of two places of habitation.       ... A, a majority shareholder of the corporation, in order for the loan to be a loan described in subparagraph 15(2)(a)(ii) of the Act.       ...

23 August 1989 Ministerial Letter 89M08018 F- 1989 Trust Return and Guide Unedited CRA Tags n/a   August 23, 1989 TO- J.M. ... Cockell Director Technical Interpretations Division Legislative and IntergovernmentalAffairs Branch   APPENDIX 1   Greg Middleton   August 23, 1989 T3 GUIDE- CREDITS- LINES 85 TO 89-      A comment should be inserted somewhere in the T3 Guide to cover capital gains refunds for mutual fund trusts which are calculated on form T184.  Presumably, the refund would be entered on line 89 on page 1 of the T3 Return.-      Under Line 86, add the phrase "on income earned by the trust" to the first line thereunder after the word "source" and consider rewording line 4 for clarity "...is not available.  ...

Harding   (613) 957-3499 Attention:  John Pruyn   File No. 7-3848 SUBJECT:  Withdrawal form a U.S.A. ... Please refer to Interpretation Bulletin 280 and Information Circular 77-1R3, para. 59; and 2.       ... For this period, the findings in the case of Hogg would have prevailed and amounts which vested in the beneficiary should have been taxed to her.       ...