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We have discussed this matter with Finance, however, should XXXXXXXXXX wish to pursue this matter we would suggest that he write to Finance at the following address: Tax Policy & Legislation Branch Department of Finance 140 O'Connor Street L'Esplanade Laurier 17th Floor, East Tower Ottawa, Ontario K1A 0G5 R. ...

Les faits XXXXXXXXXX Votre position Basé sur le bulletin d'interprétation IT-80 et l'affaire Livingston, 92 DTC 6197, XXXXXXXXXX% des intérêts réclamés par XXXXXXXXXX sur le billet contracté pour racheter les actions seraient déductibles en vertu de l'alinéa 20(1)c) de la Loi, soit le total du capital versé des actions rachetées et des bénéfices non répartis le XXXXXXXXXX divisé par le montant du billet contracté pour le rachat (XXXXXXXXXX $). ...

Prepared by: Tim Kuss Date: December 6, 1994 File # 943077 ...

In our view, the words ".. of the taxpayer" used in paragraph 20(1)(bb) of the Act describe a specific share or security which must be of the taxpayer and not for example his RRSP; what is intended is that the taxpayer who is seeking the advice from the investment counsel be the same taxpayer that is proposing to buy or sell the specific share or security. ...

With regards to the withholding requirements, we would refer you to paragraph 14 of Interpretation Bulletin IT-337R2 wherein it states "..., a person paying a retiring allowance is required to report the amount paid on form T4A supplementary and to withhold tax therefrom in such amount as is prescribed by Regulation. ...

Oulton Section Chief Business, Property & Personal Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch- 2- ...

In the alternative should it be considered that an eligible contribution is not made to a LPP where the employer's share of the LPP is funded through the consolidated revenue fund and no cash payment is made, then it is our opinion that subsection 147.2(2) of the Act would not have application and a recommendation by an actuary would not be required. for Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

Oulton Section Chief Business, Property & Personal Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

Oulton Section Chief Business, Property & Personal Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

With regards to the withholding requirements, we would refer you to paragraph 14 of Interpretation Bulletin IT-337R2 wherein it states "..., a person paying a retiring allowance is required to report the amount paid on a form T4A supplementary and to withhold tax therefrom in such amount as is prescribed by Regulation. ...