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30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS-- summary under Paragraph 4900(1)(e) Summary Under Tax Topics- Income Tax Regulations- Regulation 4900- Subsection 4900(1)- Paragraph 4900(1)(e) Index options are not qualified investments for an RRSP except in respect of the particular time, if any, when it can be clearly established that cash will be realized if the options are exercised at that time. ...

10 March 1995 External T.I. 9500835- QUALIFIED INVESTMENTS & FOREIGN PROPERTY-- summary under Paragraph 206(1)(h) Summary Under Tax Topics- Income Tax Act- Section 206- Paragraph 206(1)(h) Canadian government bonds denominated in a foreign currency are not foreign property. ...

3 October 1996 External T.I. 9628565- RRSP ADMINISTRATION & INVESTMENT MANAGEMENT FEES-- summary under Premium Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(1)- Premium annuitant's payment of management fees was a contribution The payment of investment management fees of an RRSP by the annuitant will be treated (unlike the payment by the annuitant of administration fees) as the payment of a premium to the RRSP. ...

3 October 1996 External T.I. 9628565- RRSP ADMINISTRATION & INVESTMENT MANAGEMENT FEES-- summary under Subsection 146(8) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(8) Where funds inside an RRSP (or RRIF) are used to pay administration fees, no benefit or amount is received by the annuitant as a consequence thereof. ...

3 October 1996 External T.I. 9628565- RRSP ADMINISTRATION & INVESTMENT MANAGEMENT FEES-- summary under Subsection 146.3(2) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(2) Payment by an annuitant of the fees charged for the management of property of an RRIF would be prohibited by s. 146.3(2)(f) and would result in an inclusion in income of the annuitant equal to the fair market value of the RRIF property. ...

3 October 1996 External T.I. 9631565- FEES FOR RRSP & RPP-- summary under Subsection 146.3(11) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(11) Expenses relating to the administration or management of the property in an RRIF will result in an income inclusion to the annuitant pursuant to s. 146.3(11). ...

10 February 1994 Internal T.I. 9316307 F- Indians — Taxation of Income from Various Sources-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) Discussion of the four tests that are applied by the courts in distinguishing between a contract of service and a contract for services. ...

31 July 1995 External T.I. 9518505- PUSH-DOWN ACCOUNTING & PART I.3-- summary under Subsection 181(3) Summary Under Tax Topics- Income Tax Act- Section 181- Subsection 181(3) Where balance sheet amounts have been written up through the application of push-down accounting as sanctioned by section 1625 of the CICA Handbook, such amounts will be used in the computation of large corporations tax. ...

10 May 2001 Internal T.I. 2001-0065827 F- FINES + PENALTIES- INTÉRETS ET PÉNALITÉS-- summary under Paragraph 18(1)(t) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(t) s. 18(1)(t) enacted for greater certainty CRA noted that Ioegen (96 DTC 1993) found that s. 18(1)(t) was enacted for greater certainty. ...

10 March 1999 External T.I. 9829125- PRICE ADJUSTMENT CLAUSE & 80(2)(G)-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date Although a price adjustment clause may be used for satisfying the requirements of s. 80(2)(g), "an acceptable price adjustment clause should not involve the cancelling of issued shares or the issuing of additional shares". ...