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This is evidenced by the precise wording of the provision which states in part: "(...) such of the trustees as the Minister may designate shall, for the purposes of this Act, be deemed to be in respect of all the trusts an individual whose property is the property of all the trusts and whose income is the income of all the trusts. ...

V Ltée verse annuellement à C Inc. une somme de 1 000 $ en considération de l'éxécution de son mandat. 8. ...

The Department made the following comments, which are still applicable to date, on this issue: "... ...

Kauffman Chief Leasing & Financing Section Financial Industries Division Rulings Directorate ...

Chief Resource Industries Section Bilingual Services & Resource Industries Division Rulings Directorate c.c. ...

Yours truly, for Director Reorganization & Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

In this letter you describe the following hypothetical situation: 1) A corporation (A Co.) is a Canadian-controlled private corporation, within the meaning of paragraph 125(7)(b) of the Act. 2) The assets of A Co. are: Term deposits $ 265,000 Inventory 3,000 Amounts due from related companies 1,424,000 Prepaid expenses 5,000 Fixed assets, at cost $442,000 Less depreciation 228,000 214,000 Investment in subsidiary 10,000 Deferred income taxes 16,000 1,937,000 3) A Co. carries on a business in Canada. ...

Yours truly, for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch Document Disclosed Pursuant to the Access to Information Act Document Divulgué en vertu de la loi sur l'accès à l'informationLANGIND E DOCNUM AC59207 REPLACES TYPEKEY R AUTHORDV LEGS AUTHOR PLEE DESCKEY 5 RATEKEY 1 REFDATE 900205 ETADYEAR ETADSORT ADMINACC LEGS ACCESSLV LEGS99 SUBJECT Loss on disposition of a property which is a loan SECTION ITA-18(13) SECTION SECTION SECTION SECTION $$$$ 5- 9207 19(1) Peter Lee (613) 957-2745 February 5, 1990 Dear Sirs: Re: Subsection 18(13) of the Income Tax Act (the "Act") Loss on Disposition of a Property Which is a Loan We are writing in reply to your letter of December 4, 1989, wherein you requested our opinion as to whether subsection 18(13) of the Act would deny a loss on disposition of a property which is a loan, only to the extent that the loss exceeds any paragraph 20(1)(1) reserve previously claimed. ...

It is intended that Bco transfer the following properties to Aco under a reorganization that would be carried out pursuant to paragraph 55(3)(b) of the Act: Fair Market Liabilities Allocated Tax Cost Value Specific Non-Specific Property 1 $ 1 2,000 1,000 300 Property 2 2,000 4,000 600 The reorganization will be carried out on a "net equity basis", whereby each of the properties will be transferred net of its respective liabilities. ...

Olympia floor & Wall Tile v. M.N.R. [[1970] C.T.C. 99] 70 DTC 6085 24(1) 23 We see no competition between equally applicable provisions of the law in the other two cases. ...