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. … [T]he custodian of an RCA who holds a letter of credit would not be able to make the election under subsection 207.5(2). ...

For example [there would be such] benefit … if one of the conditions of remaining a capital beneficiary was to continue to be employed by Opco, so as to render services to Opco.... ...

. … [P]aragraph 248(3)(f) essentially restates what subsection 248(3) provided at the time, except that the wording is now different and cannot be interpreted as in the Construction Bérou Inc. case. ...

. … Consequently, any compensation received by a taxpayer pursuant to Article 1617 of the CCQ constitutes interest income to the taxpayer (see No. 484 v. ...

21 November 2001 External T.I. 2000-0062895 F- BOURSE D'ETUDES OU REVENU D'EMPLOI-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) “scholarships” that had to be repaid if the student did not then work for the employer were received qua employee – but could be non-taxable as primarily for employer’s benefit A professional services firm recruits university students and offers them a sum of money to cover the cost of their studies. ...

21 January 2002 External T.I. 2001-0078735 F- Droit de recevoir une somme-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 54- Proceeds of Disposition FMV of contingent right to deferred cash sales proceeds was included in proceeds, with subsequent gain or loss when the contingency was resolved The shareholders of a Canadian-controlled private corporation (Xco) agreed to sell their Xco shares to a public corporation (Yco) in consideration for an upfront cash payment, and for shares of Yco received on an s. 85(1) rollover basis – but with a clause (the “Clause”) in the sale agreement providing that in one year’s time they would receive a further cash payment for each of their Yco shares equal to the deficiency in its trading price in one year’s time as compared to the portion of the sale price allocated to such shares. ...

21 January 2002 External T.I. 2001-0078735 F- Droit de recevoir une somme-- summary under Paragraph 12(1)(g) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) s. 12(1)(g) inapplicable to contingent right to receive deferred cash sales proceeds to the extent the share consideration declined in value The shareholders of a CCPC (Xco) agreed to sell their Xco shares to a public corporation (Yco) in consideration for an upfront cash payment, and for shares of Yco received on an s. 85(1) rollover basis – but with a clause (the “Clause”) in the sale agreement providing that in one year’s time they would receive a further cash payment for each of their Yco shares equal to the deficiency in its trading price at that time as compared to the portion of the sale price allocated to such shares. ...

21 January 2002 External T.I. 2001-0078735 F- Droit de recevoir une somme-- summary under Paragraph 85(1)(f) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(f) s. 85(1)(f) applicable to contingent right to receive deferred cash sales proceeds to the extent the share consideration received under s. 85(1) declined in value The shareholders of a CCPC (Xco) agreed to sell their Xco shares to a public corporation (Yco) in consideration for an upfront cash payment, and for shares of Yco received on an s. 85(1) rollover basis – but with a clause (the “Clause”) in the sale agreement providing that in one year’s time they would receive a further cash payment for each of their Yco shares equal to the deficiency in its trading price at that time as compared to the portion of the sale price allocated to such shares. ...

10 January 2002 External T.I. 2001-0112885 F- ASSURANCE-VIE ET PRET REMBOURSE AU DECES-- summary under Subsection 207.6(2) Summary Under Tax Topics- Income Tax Act- Section 207.6- Subsection 207.6(2) overview of employer use of life insurance policy to fund RCA benefits CCRA provided the following overview of the use of a life insurance policy to fund an RCA: [W]here an employer acquires an interest in a life insurance policy to enable it to fund benefits to be received by a person on or after a taxpayer's retirement … [t]he provisions of Part XI.3 then apply. ...

5 April 2002 External T.I. 2002-0122055 F- BIEND D'UN REER DONNES EN GARANTIE-- summary under Subsection 146(10) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(10) s. 146(10) rather than s. 146(12) applies to a non-depositary RRSP where its property is used as security In the course of a general discussion of the consequences of an RRSP permitting its property to be used as security, CCRA drew a distinction between the consequences to a depositary and non-depositary RRSP, indicated that s. 146(12) rather than s. 146(10) applies to a depositary RRSP in this situation and then stated that: [such] rules … do not apply in the case of a trust governed by an RRSP described in subparagraph (b)(i) of the definition of "retirement savings plan" in subsection 146(1). ...