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21 September 1990 Administrative Letter 901486 F- Qualified Small Business Corporation Share Unedited CRA Tags 110.6(1) qualified small business corporation share, 248(1) small business corporation, 248(5)(a)   September 21, 1990 KITCHENER DISTRICT OFFICE Rulings Directorate Audit Review C. Tremblay   952-1361 J. Fyfe   901486   EACC9682 Subject: Qualified Small Business Corporation Share This is in reply to your memorandum of June 28, 1990, and further to a telephone conversation of August 22, 1990, (Tremblay/Fife) concerning the above "definition" in the situation where there is more than one holding company involved. ...

27 August 1993 Administrative Letter 9323666 F- Tax Treaty Negotiation Seminar (HAA 4093-U5-100-4) Unedited CRA Tags OECD Article 4, 250(3) MEMO FOR FILERulings Directorate Tax Treaty Negotiation Seminar (August 30 to September 3) Summary of Canadian Residence Concepts (Appendix A) Summary of the XXXXXXXXXX Case (Appendix B) Ken Major was asked to give a lecture concerning Articles 4 & 5 of the OECD Model Income Tax Convention in the above mentioned seminar organized with CIDA assistance for the XXXXXXXXXX The attached Appendixes were prepared, on an informal basis, as a handout for the participants during Mr. ... While the following list does not purport to be exhaustive, material factors include: 1) Permanence & Purpose of the Stay Abroad-     must be a degree of permanence to absence from Canada- return to Canada foreseen at time of departure- guaranteed employment upon return to Canada- status with Employment and Immigration Canada 2) Residential Ties Within Canada-     dwelling place (or places)- spouse and dependants- friends and family- personal property (furniture, automobile, clothing, etc.)- economic ties (employment, union membership, business, investments)- financial services (bank accounts, credit cards, safety deposit box)- social ties (membership in professional, social, recreational, or religious organizations)- provincial and private medical coverage- social security coverage- driver's licences- telephone listings- subscriptions to newspapers and other periodicals- Canadian burial plots 3) Residential Ties Outside Canada-     everyone must be resident somewhere- it is possible to be a dual resident 4) Regularity & Length of Visits to Canada-     status generally not affected by occasional return visits to Canada- return visits on a regular basis may indicate a continuing resident Residence of Corporations Like individuals, the Canadian residence status of corporations, for purposes of the Income Tax Act and excluding certain deeming provisions (e.g. corporations incorporated in Canada are generally deemed to be resident in Canada), is a question of fact.  ...

14 August 1989 Administrative Letter 74106 F- Taxability of Government Annuity Unedited CRA Tags 56(1)(a)(i)   August 14, 1989 VANCOUVER DISTRICT OFFICE HEAD OFFICE Office Examination Section Rulings Directorate J. Jerczynski Financial Industries Division   W.C. Harding   (613) 957-3499 Subject:  19(1) Taxability of Government Annuity This is in reply to your memorandum of June 23, 1989 which was referred to our Division for reply. ...

Monsieur X, un résident canadien, détient 100% des actions du capital-actions de Holdco, une corporation privée depuis plus de 24 mois. 2.     Holdco détient 70% des actions de Opco, une autre corporation privée depuis plus de 24 mois. 3.     Les éléments d'actif de Holdco, en terme de valeur marchande, sont les suivants, et ce depuis 24 mois: placements 2 000 000$ 36% actions de Opco 3 500 000    64%   5 500 000$  100% 4.      ...

15 January 1990 Administrative Letter F3306 F- Investment Tax Credit and Settlement of Debts Unedited CRA Tags 80(1), 127(11.1)   January 15, 1990 Mr. ... Dath Current Amendments and Director Regulations Division Business and General Division   D.C. Burnett (957-2078)   F3306/3363 Subsections 80(1) and 127(11.1) of the Income Tax Act This is in response to the memorandum of September 25, 1989 prepared by C. ...

Kotlar, Director Division   D. S. Delorey   957-8953 Attention:  R. Grabs   7-912741 Allocation of Plan Earnings This is in reply to your memorandum of September 25, 1991 and further to our (Grabs/Delorey) telephone conversation on March 5, 1992. ...

Harding   (613) 957-3499 October 3, 1989 Dear Sirs: Re:  Technical Interpretation Subsection 70(6.2) of the Income Tax Act (the "Act") This is in reply to your letter of June 2, 1989, in respect of the above noted topic as it relates to the following situation: 1.      ... Pursuant to her Will, she bequeaths her interest in land and an "Adjacent building" to her spouse, B. 2.      ... You requested a technical interpretation as to whether: a)     Upon the election by A's executors pursuant to subsection 70(6.2) an undivided 10% interest in the land may be transferred at its fair market value; b)     Subsection 70(6) of the Act will not apply to the transfer of that portion of the land; and c)     Subsection 70(6) will apply to the transfer of a 90% interest in the land and a 100% interest in the "adjacent building". ...

However, we may offer the following general comments. 1.     The percentage mentioned in subparagraph 6801 (a)(ii) of the Regulations is to be applied to gross earnings (salary or wages). 2.      ... Since the Regulations are very specific on this subject, 24(1) 3.     It is our opinion that the provisions of subparagraph 6801(a)(iii) of the Regulations would not be contravened where the inclusion of an interest element in instalment payments is make to a participant of a plan during his leave of absence 24(1) 4.     24(1) The Plan must not permit voluntary withdrawals since this may indicate that one of the main purposes of the Plan is to defer taxes rather than permit employees to fund a leave of absence. 5.      ...

Leung   (613) 957-2116 March 12, 1990 Dear Sirs: Re: Subsections 49(1) and 85(1) of the Income Tax Act (the "Act") We are writing in response to your letter of December 6, 1989 wherein you requested our view as to whether subsection 85(1) of the Act would be applicable to the granting of an option to which subsection 49(1) of the Act applies in the following hypothetical situation as described in your letter. 1.      ... "Taxable Canadian corporation" and "cost amount" have the meanings assigned by paragraph 89(1)(i) and subsection 248(1) of the Act, respectively. 2.      ... A. will receive shares of Subco having a fair market value of $10. 3.      ...

30 April 1990 Administrative Letter 32946 F- Advance Income Tax Ruling Request Unedited CRA Tags n/a 19(1) File No. 3-2946   Kevin J. Donnelly   (613) 957-3400 April 30, 1990 Dear Sirs: Re: 24(1) Advance Income Tax Ruling Request This is to confirm your April 25, 1990 telephone call advising that your ruling request dated January 25, 1990 on behalf of the corporation named above is withdrawn. ...