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21 January 2002 External T.I. 2001-0078735 F- Droit de recevoir une somme-- summary under Paragraph 85(1)(f) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(f) s. 85(1)(f) applicable to contingent right to receive deferred cash sales proceeds to the extent the share consideration received under s. 85(1) declined in value The shareholders of a CCPC (Xco) agreed to sell their Xco shares to a public corporation (Yco) in consideration for an upfront cash payment, and for shares of Yco received on an s. 85(1) rollover basis – but with a clause (the “Clause”) in the sale agreement providing that in one year’s time they would receive a further cash payment for each of their Yco shares equal to the deficiency in its trading price at that time as compared to the portion of the sale price allocated to such shares. ...

10 January 2002 External T.I. 2001-0112885 F- ASSURANCE-VIE ET PRET REMBOURSE AU DECES-- summary under Subsection 207.6(2) Summary Under Tax Topics- Income Tax Act- Section 207.6- Subsection 207.6(2) overview of employer use of life insurance policy to fund RCA benefits CCRA provided the following overview of the use of a life insurance policy to fund an RCA: [W]here an employer acquires an interest in a life insurance policy to enable it to fund benefits to be received by a person on or after a taxpayer's retirement … [t]he provisions of Part XI.3 then apply. ...

“[I]t is not necessary for the purposes of subparagraph 122.3(1)(b)(i) that this contract be with the person who undertakes the qualifying activities or that the qualifying activities be undertaken directly by the specified employer under this contract, as long as the services provided by the specified employer under the contract to which it is a party are related to a contract entered into by another party with respect to those qualifying activities ….” ...

12 March 2002 Internal T.I. 2001-0094067 F- DEDOMMAGEMENT- TITRE DE PROPRIETE-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 54- Proceeds of Disposition damages received for use of a property contrary to the recipient’s co-ownership right were tax-free receipts After his discovery that his separated common-law spouse (Madame) was selling a property in which he had a ½ co-ownership interest, Monsieur obtained a judgment requiring recognition through a deed of his co-ownership interest and a second judgment requiring her to account for her management of the property in the interim, which resulted in Monsieur receiving a lump-sum damages payment. ...

Before concluding that such terminal loss should be denied because the building did not qualify as depreciable property (it was not acquired for rental-income purposes notwithstanding its temporary generation of rents), the Directorate stated: [M]ost of the moving costs … should be added to the cost of the cleared land since the purpose of the move was to clear the land rather than to advantageously locate the building. ...

In finding that such compensation was taxable to them (and likely employment income rather than business income), the Directorate stated: [T]he reward received by the crew members was not a windfall …. ...

5 April 2002 External T.I. 2002-0122055 F- BIEND D'UN REER DONNES EN GARANTIE-- summary under Subsection 146(10) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(10) s. 146(10) rather than s. 146(12) applies to a non-depositary RRSP where its property is used as security In the course of a general discussion of the consequences of an RRSP permitting its property to be used as security, CCRA drew a distinction between the consequences to a depositary and non-depositary RRSP, indicated that s. 146(12) rather than s. 146(10) applies to a depositary RRSP in this situation and then stated that: [such] rules … do not apply in the case of a trust governed by an RRSP described in subparagraph (b)(i) of the definition of "retirement savings plan" in subsection 146(1). ...

CCRA indicated that such exchange would not constitute a disposition of her interest (and that there was no transfer of her interest for purposes of s. 97(2),) given that “the exchange … serves to isolate the units relating to the rights in the shares that Ms. ...

CCRA indicated that such exchange would not constitute a disposition of her interest, and that there was no transfer of her interest for purposes of s. 97(2), given that “the exchange … serves to isolate the units relating to the rights in the shares that Ms. ...

. … [T]he estate's first taxation year is the subsequent taxation year referred to in subparagraph 161(7)(a)(iv.2) and subparagraph 161(7)(b)(ii). ...