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18 December 1989 Administrative Letter 58836 F- Deductibility of Personal Financial Planning Services Unedited CRA Tags 20(1)(bb), 9(1) 19(1) 5-8836   M. Eisner   (613) 957-2138 December 18, 1989 Dear Sirs: This is in reply to your letter of October 4, 1989 concerning the deductibility if the cost of personal financial planning services. ...

18 July 1989 Administrative Letter 58136- Déductibilité des frais de déplacement Unedited CRA Tags 8(1)(h), 6(1)(b)(vii.1), 3, 5, 7 19(1) File No. 5-8136   A.M. ... Pour qu'un contribuable soit en droit de réclamer ses frais de déplacement en vertu de l'alinéa 8(1)h) de la Loi, il doit respecter trois conditions, soit: 1.      ... a été tenu, en vertu de son contrat d'emploi, d'acquitter les frais de déplacement engagés par lui pour l'accomplissement des fonction de don emploi et 3.      ...

18 May 1990 Administrative Letter 74726 F- Distribution of Proceeds of Realization to Secured Creditor Unedited CRA Tags 159(2), 159(3), 150(3)   May 18, 1990 TORONTO DISTRICT OFFICE HEAD OFFICE P. ... Robb   (613) 957-2744   File No. 7-4726 SUBJECT:  24(1) Application of subsections 159(2) and (3) of the Income Tax Act (Canada) (the "Act") We are writing in response to your memorandum of February 15, 1990 concerning the application of subsection of subsections 159(2) and (3) in respect of certain transactions of the 24(1)  The facts as we understand them are as follows: Facts 24(1) Your Views In your view, 24(1) You have also requested our comments on Mr. ... ClarkChiefLeasing & Financing SectionFinancial Industries DivisionRulings Directorate   ...

18 December 1989 Administrative Letter 59166 F- Redemption of Shares at less than FMV Unedited CRA Tags 40(1), 54 proceeds of disposition, 69(1)(b), 84(3), 84(9), 110.6(7) 19(1) File No. 5-9166   S. Leung   (613) 957-2116 December 18, 1989 Dear Sirs: Re:  Paragraph 69(1)(b) and subsection 84(3) of the Income Tax Act (the "Act") We are writing in response to your letter of November 24, 1989 wherein you requested our opinion as to whether paragraph 69(1)(b) of the Act would apply to the following situation which was outlined in your letter. Situation 24(1) Our Comments It is the Department's view that paragraph 69(1)(b) of the Act will apply to a disposition of shares of a corporation which are disposed of in a manner as described in subsection 84(9) of the Act, if (i)     the shareholder who disposes of the shares is not dealing at arm's length with the corporation, and (ii)     the proceeds of disposition of the shares (i.e. the redemption price) is less than their fair market value at the time of their disposition, notwithstanding that subsection 84(3) of the Act might also apply to the acquisition of its own shares by the corporation.  ...

Collin- Adverse Decision Unedited CRA Tags 62(3)(e)   August 1, 1990 Appeals and Referrals Division Current Amendments and   Regulations Division L.C. ... Adler Acting Director 957-2066   F-3746 The Queen v. Merton A. Collin Adverse Decision of the Federal Court- Trial Division This is in reply to the memorandum of June 18, 1990, prepared by Josephine Yu, concerning the treatment of a prepayment of mortgage interest as a selling cost for purposes of paragraph 62(3)(e) of the Income Tax Act. 21(1)(b) B.J. ...

Afin de déterminer s'il y a disposition d'un intérêt dans une police d'assurance, il faut s'en remettre à la définition de " disposition " au paragraphe 148(9). ...

23 October 1991 Administrative Letter 912346 F- Penalty Provisions in Connection with Collection Procedures Unedited CRA Tags 239(1(d),162(7)(b), 159(2),159(3) Application of 239(1(d) & 162(7)(b) to 159(2) & (3) Further to our telephone conversation of October 18, 1991, withEr. ... We examined our research files and found that the possibility of applying these penalty provisions in 159(2) & (3) situations had never been addressed by this Directorate. ...

24 November 1989 Administrative Letter 58996 F- Acquisition of Control Unedited CRA Tags 249(4), 256(7) 19(1) File No. 5-8996   P. ... Facts 1.     Mr. A is the sole shareholder of Company A, a taxable Canadian corporation. 2.      ... A transfers all of his shares of Company A to Company X and receives as consideration therefore, 55% of the voting shares of Company X, a taxable Canadian corporation. 3.      ...

3 October 1990 Administrative Letter 59816 F- Exchange Loss or Gain Unedited CRA Tags 39(2), 53(2)(b)(ii), 40, 39(1) 24(1) 5-9816   G. Kauppinen   (613) 957-2117 19(1) October 3, 1990 Dear Sirs: This is in reply to your letter dated March 19, 1990 wherein you request our opinion regarding the application of subsection 39(2) and subparagraph 53(2)(b)(ii) of the Income Tax Act (the "Act") in the following circumstances: 1.     The taxpayer is a corporation (the "Shareholder") incorporated in and a resident of Canada for the purposes of the Act. 2.      ...

The only assets owned by AB Co. are: (1) a building with a tax cost of $1 and a fair market value of $100,000; and (2) a business having shareholder's equity of $1 and a fair market value of $100,000 made up of goodwill with a value of $100,000 and no tax cost.     ... No other shares of Newco will be issued, except for preferred shares with a paid-up capital of $1 and a redemption value of $100,000 to be issued to AB Co.to complete the transfer of the building to Newco on a tax- deferred basis under section 85 of the Act.     ... Paragraph 55(3)(a) of the Act provides, in general terms, that subsection 55(2) will not apply to a dividend received by a corporation if the dividend was received as part of a series of transactions or events that did not result in     (i) a disposition of any property to a person with whom the corporation which received the dividend was dealing at arm's length,     or     (ii) a significant increase in the interest in any corporation of any person with whom the corporation which received the dividend was dealing at arm's length. ...