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19 February 1980 Income Tax Severed Letter RCT 5-1149 F Unedited CRA Tags 85(1), 85(1)(i) Dear Sirs: RE:     Effect of Notice of Ways and Means Motion #33 on Advance Income Tax Ruling- XXX Charitable Foundation This is in reply to your letter of January 22, 1980 concerning the above subjects. ...

22 February 1985 Income Tax Severed Letter RCT 85-029 F Unedited CRA Tags 85.1 RE:     85.1 and IT-450 In the course of a share for share exchange pursuant to section 85.1 when the vendor receives shares for some of the exchanged shares and cash or other consideration for other exchanged shares, paragraph 5 of IT-450 indicates that 85.1(1) may be used in respect of the exchanged shares for which shares were received, provided the vendor can clearly identify which shares were exchanged for cash or other consideration and which were exchanged for shares. ...

11 June 1981 Income Tax Severed Letter RCT 5-2698 F Unedited CRA Tags 89(1)(f), 125(6)(a), 125(3), 125(4), 15.1(3)(a) Dear Sir: RE:     XXX This is in reply to your letter dated May 7, 1981 in which you request, as treasurer of the above-mentioned corporation, opinions in respect of the following: A. ...

21 May 1985 Income Tax Severed Letter RCT 5-7518 F Unedited CRA Tags 55(2) Dear Sirs: RE:     Subsection 55(2) of the Income Tax Act This is in response to your letter of February 8, 1985 wherein you requested our views as to the amount of a dividend received which would be deemed to be proceeds of disposition pursuant to paragraph 55(2)(b) of the Act in the following hypothetical situation: 1. ...

23 February 1986 Income Tax Severed Letter RCT 5-0266 F Unedited CRA Tags 40(1)(a)(iii) Dear XXX: RE:     Capital Dividend Account This is in reply to your letter of December 11, 1985 concerning whether or not a capital gain reserve that is to be brought into income at the end of the taxation year should be taken into consideration in the calculation of the Capital Dividend account that may be calculated at any particular time in the year. ...

11 January 1984 Income Tax Severed Letter RCT 5-5747 F Unedited CRA Tags 84.1, 85(1) Dear XXX: RE:     Section 84.1 We are writing in response to your letter of November 22, wherein you enquired whether we would be prepared to rule concerning the application of section 84.1 in circumstances similar to the example set out in your letter. ...

1 May 1984 Income Tax Severed Letter RCT 5-6146 F Unedited CRA Tags 84(1) Dear Sirs: RE:     Determination of paid-up capital This is in response to your letter of March 13, 1984 wherein you requested our views with respect to the classification for purposes of the Income Tax Act (the "Act") of a capital redemption reserve fund under the Alberta Companies Act (the "ACA") and on continuance under the Alberta Business Corporations Act (the "ABCA"). ...

6 November 1984 Income Tax Severed Letter RCT 5-7038 F Unedited CRA Tags 85(1) Dear Sirs: RE:     Subsection 85(1) In your letter of November 6, 1984 you requested our opinion concerning whether subsection 85(1) could be used to transfer a right to income that arises in the following circumstances. ...

17 June 1986 Income Tax Severed Letter RCT 7-0658 F Unedited CRA Tags 247(1) RE:     Deductibility of Interest, Application of Subsection 247(1) This is in reply to your memorandum of May 20, 1986 to which you have attached a copy of a letter from XXX dated May 12, 1986. ...

25 April 1980 Income Tax Severed Letter RCT 5-1371 F Unedited CRA Tags 85(1) Dear XXX: RE:     Issuance of shares pursuant to subsection 85(1) of the Income Tax Act (the Act) This is in reply to your letter of March 27, 1980 requesting an opinion on a situation where shares are not issued concurrent with the conveyance of the assets in a subsection 85(1) rollover. ...