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31 March 1995 External T.I. 9430115- interest in a family farm partnership & capital gains RESERVE-- summary under Subparagraph 40(1)(a)(iii) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(1)- Paragraph 40(1)(a)- Subparagraph 40(1)(a)(iii) A reserve may not be claimed where an individual transfers property to a partnership pursuant to s. 97(1) and receives as consideration a promissory note payable over five years. ...

20 December 1995 External T.I. 9526825- ENTRY FEE PAYMENTS & WITHHOLDING TAX-- summary under Paragraph 212(1)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d) Discussion of factors bearing on whether surface lease payments are on account of capital (e.g., lump sum payments received as compensation for injurious affection of land that are treated as proceeds of disposition for purposes of s. 115(1)(b)(i)) or on account of income (subject to withholding tax under s. 212(1)(d)). ...

20 December 1995 External T.I. 9526825- ENTRY FEE PAYMENTS & WITHHOLDING TAX-- summary under Real Estate Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

& Section 116116(5)-- summary under Subsection 49(3) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(3) S.49(3) did not apply to deem the exercise of employee stock options held by a non-resident former employee to not be a disposition of the options, given that s. 49(3) applied only to capital property, whereas employee stock options are governed by s. 7. ...

18 December 2001 External T.I. 2001-0073925- Paragraph 88(1)(e.2) & Subsection 186(5)186(5)-- summary under Subsection 186(5) Summary Under Tax Topics- Income Tax Act- Section 186- Subsection 186(5) "While subsection 186(5) does not specifically refer to paragraph 88(1)(e.2) it is our view that such reference is not necessary. ...

2001 Ruling 2001-0077753- DIRECTORS FEES & STOCK OPTIONS-- summary under Paragraph 7(1)(a) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(a) options received on behalf of partnership Confirmation that where employees of the general manager of two partnerships sit on the board of directors of corporations on behalf of their employer, they are not required to report directors' fees and stock options paid to them as directors of the company. ...

1 May 2002 External T.I. 2002-0133145 F- RAP- BAIL & ACTIONS-- summary under Qualifying Home Summary Under Tax Topics- Income Tax Act- Section 146.01- Subsection 146.01(1)- Qualifying Home unit consisting of a leasehold interest and shares of the corporation owing the property could qualify as qualifying home Regarding the purchase of a unit that consisting of a leasehold interest in the property and a number of shares in the corporation that owns the property, CCRA noted that advance rulings had found that a unit consisting of a leasehold interest and shares, and giving its holder the right to the personal enjoyment of the housing unit would be a housing unit for the purposes of the definition of "principal residence", and that the acquisition of such a unit could qualify as a qualifying home for HBP purposes. ...

2 October 2002 Internal T.I. 2002-0135807 F- Lumpsum Somme Forfaitaire Reg 102 / 103-- summary under Paragraph 103(4)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 103- Subsection 103(4)- Paragraph 103(4)(c) withholding on retiring allowance paid in periodic instalments determined under Reg. 102(1) Where a retiring allowance of $30,000 was paid in 30 equal weekly payments of $1,000 to a Quebec employee, the Directorate determined that the rate of withholding would be determined under Reg. 102(1) on the basis of being periodic payments of $1,000 rather than pursuant to Reg. 103(4)(c)(i) as a lump sum payment over $15,000. ...

7 February 2000 External T.I. 2000-0000555- NURSING HOME FEES-FOOD & ACCOM.-- summary under Paragraph 118.2(2)(b) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(b) "Generally, all regular fees charged by a nursing home, including any component for accommodation or meals, are normally accepted as being on account of full-time care in a nursing home. ...

19 March 2001 External T.I. 2001-0063345 F- RS & DE- MANDATAIRE-- summary under Clause 37(1)(a)(ii)(E) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1)- Paragraph 37(1)(a)- Subparagraph 37(1)(a)(ii)- Clause 37(1)(a)(ii)(E) organization did not qualify under s. 37(1)(a)(ii)(E) because it made disbursements only as agent The applicant did not qualify under s. 37(1)(a)(ii)(E) because it disbursed amounts to other entities only as agent for taxpayers and thus did not “carry on activities that consist of receiving amounts from taxpayers, other than as an agent of the taxpayers, and redistributing those amounts to the associations, institutions or corporations referred to in clauses 37(1)(a)(ii)(A) to (C).” ...