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25 July 1986 Income Tax Severed Letter RCT 5-1489 F Unedited CRA Tags 85(4), 85(4)(x), ITAR 26(7) Dear Sirs: RE:     Disposition of shares on the winding-up of a corporation This is in reply to your letter of April 24, 1986 and further to your telephone call of July 15, 1986 requesting a technical interpretation of certain provisions of the Income Tax Act as they may apply to a transaction based on the following hypothetical facts: Mrs. 'A' owns all of the shares of X Corporation. Paid up capital of shares $ 1,000 Fair market value of shares on December 31, 1971 $ 300,000 Value of assets to be distributed $1,000,000 Mrs. 'A' has elected pursuant to subsection 26(7) of the Income Tax Application Rules with respect to the capital cost to her of capital properties owned on December 31, 1971. ...

Question 2 What does the reference to "... one of the main purposes... ... Question 3 What is the meaning of the words "... in order to increase the degree of control... ... Question 4 What circumstances or transactions would "... increase the degree of control... ...

8 November 1983 Income Tax Severed Letter RCT 89-086 F Unedited CRA Tags 89(1)(b)(i)(B)(I) RE:     Capital Dividend Account This is in reply to your round-trip memorandum dated October 7, 1983 in which you asked whether a business investment loss is a capital loss that needs to be taken into account under subclause 89(1)(b)(i)(B)(I) in computing the capital dividend account. ... Diguer, Assistant Deputy Minister, Policy & Systems Branch ...

1 November 1991 Income Tax Severed Letter 91M11260 F- Deduction of Accruals under GAAP for Mining Site Restoration Costs QUESTION 1.        ... Such accruals are necessary to achieve proper matching of revenues and expenses.     ... ANSWER 1.        The requirement by provinces for site restoration, by itself, does not give rise to an expense.  ...

As indicated in Re Rispin ((1912) 25 O.L.R. 633, 2 D.L.R. 644; affirmed 46 S.C.R. 649, 8 D.L.R. 756: The cases bearing upon similar questions [...] are numerous, and one might even say sometimes embarrassing, if not conflicting. [...] ... The instructions given for the opening of the account were as follows: "Look at my account current, and [...] make a purchase in some public stock [...] for my boy Lionel Eldred, who is this day twelve months old. Let it be in my own name and in my wife's, [...] in trust for Lionel Eldred Smith". ...

17 February 1987 Income Tax Severed Letter RCT 5-1978 F Unedited CRA Tags 84.1 Dear Sirs: RE:     Section 84.1 of the Income Tax Act (the "Act") This is in reply to your letter of July 29, 1986 in which you requested our interpretation of the words "... was a share substituted for such a share... ... A would be substituted property for the non-voting shares for purposes of determining whether there has been "... a share substituted for such a share... ...

11 June 1985 Income Tax Severed Letter RCT 5-7592 F Unedited CRA Tags 55 Dear Sirs: RE:     Section 55 of the Income Tax Act This is in reply to your letter of April 4, 1985 wherein you requested confirmation of your understanding of the computation of "income earned or realized... after 1971" for the purposes of subsection 55(2) of the Act. ... However, viewing your example in complete isolation, we would agree with the results of your calculation subject to the following:-     losses incurred after 1971 would be deducted in determining the amount of a gain attributable to "safe income"-     dividends received will be included in the "safe income" of the recipient if received out of the "safe income" of a subsidiary. ...

3 October 1980 Income Tax Severed Letter RCT 7-532 F Unedited CRA Tags 85(1), 56(4) RE:     XXX Fractional Shares Received as Consideration for Property Transferred under Subsection 85(1)of the Income Tax Act (the Act) This is in reply to Mr. ... Consequently, an argument can be made (see Alberta & Southern Gas Co. ...

31 May 1985 Income Tax Severed Letter RCT A-0947 F Unedited CRA Tags 107(5) Dear Sirs: RE:     Subsection 107(5)- Taxable Canadian Property This is in reply to your letter of January 8, 1985. ... You point out, the general scheme of the Act contemplates the ownership of taxable Canadian property with reference to non-residents (e.g. in paragraph 48(1)(a) of the Act which refers to "... any property... that would be taxable Canadian property if at no time in the year he had been resident in Canada... ...

24 June 1982 Income Tax Severed Letter RCT-0483 F Dear Sirs: RE:     Non-Resident Corporation Receiving Rent on Real Property in Canada This is in reply to your letter of May 3, 1982 wherein you requested our opinion as to the Canadian tax consequences in respect of the following hypothetical fact situation: 1. ... P Co has elected under subsection 216(1) of the Income Tax Act, Canada ("Act") to be taxed in respect of its Canadian source rental income on a "net " basis for its 1982 taxation year ended December 31, 1982; 6. ...