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1 September 1994 External T.I. 9413775- ELIGIBLE PROPERTY & CUM DIVIDENDS-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property right to accrued dividends is not separate property from the shares In finding that the right to accrued but undeclared dividends was not a separate eligible property from the preferred shares on which they had accrued, Revenue Canada stated: The right to accrued cumulative dividends would be just one of the bundle of rights that would be attached to a particular share.... ...

30 June 1994 External T.I. 9412365- PREFERRED BENEFICIARY ELECTION & CAPITAL GAINS-- summary under Subsection 2800(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 2800- Subsection 2800(3) Respecting a situation in which the beneficiaries of a trust established by a father were the grandchildren, children and the mother, and income could be distributed at the discretion of the trustees to the mother, the children or the grandchildren in amounts decided by the trustees, RC noted that where Regulation 2800(3)(e) applies, the discretionary share of the spouse (i.e., mother) is 100% of the accumulating income (which would include taxable capital gains) regardless of the fact that there are other income and capital beneficiaries, and that she is not a capital beneficiary. ...

30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS-- summary under Subsection 146(10) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(10) Where cash is deposited as margin with a broker then, notwithstanding that such deposit would not be a qualified investment under s. 204(e)(i), s. 146(10) will not be applied to the annuitant if the transaction is concluded within a few days. ...

Dad invests $ in "trust" a/c for KIDS-- summary under Subsection 74.1(2) Summary Under Tax Topics- Income Tax Act- Section 74.1- Subsection 74.1(2) The word "transfer" means to "divest, deprive or dispossess of title". ...

17 December 1996 Internal T.I. 9625727- REMARRIAGE CLAUSE & DEF'N OF SPOUSAL TRUST-- summary under Subsection 70(6) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6) Where a will provided that the widow was entitled to receive the income of the estate but that her entitlement was "to be terminated upon her death or remarriage", and it is proposed that a court order be obtained removing the remarriage clause, RC will accept that the property of the estate vested indefeasibly in the spouse's trust within the 36-month period only if the court order is made within 36 months of the date of death. ...

31 March 1995 External T.I. 9430115- interest in a family farm partnership & capital gains RESERVE-- summary under Subparagraph 40(1)(a)(iii) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(1)- Paragraph 40(1)(a)- Subparagraph 40(1)(a)(iii) A reserve may not be claimed where an individual transfers property to a partnership pursuant to s. 97(1) and receives as consideration a promissory note payable over five years. ...

20 December 1995 External T.I. 9526825- ENTRY FEE PAYMENTS & WITHHOLDING TAX-- summary under Paragraph 212(1)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d) Discussion of factors bearing on whether surface lease payments are on account of capital (e.g., lump sum payments received as compensation for injurious affection of land that are treated as proceeds of disposition for purposes of s. 115(1)(b)(i)) or on account of income (subject to withholding tax under s. 212(1)(d)). ...

20 December 1995 External T.I. 9526825- ENTRY FEE PAYMENTS & WITHHOLDING TAX-- summary under Real Estate Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

& Section 116116(5)-- summary under Subsection 49(3) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(3) S.49(3) did not apply to deem the exercise of employee stock options held by a non-resident former employee to not be a disposition of the options, given that s. 49(3) applied only to capital property, whereas employee stock options are governed by s. 7. ...

18 December 2001 External T.I. 2001-0073925- Paragraph 88(1)(e.2) & Subsection 186(5)186(5)-- summary under Subsection 186(5) Summary Under Tax Topics- Income Tax Act- Section 186- Subsection 186(5) "While subsection 186(5) does not specifically refer to paragraph 88(1)(e.2) it is our view that such reference is not necessary. ...