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Principal Issues: Various Indian taxation issues:- employment income- investment income- business income INDIAN ACT EXEMPTION ISSUE CONFERENCE Prairie & Pacific Regions November 20- 21, 1996 INCOME TAX RULINGS AND INTERPRETATIONS DIRECTORATE Introduction The Income Tax Rulings & Interpretations Directorate is part of the Policy and Legislation Branch. ...

(footnote 1) These subsections were addressed in a comfort letter issued by the Department of Finance dated May 26, 2011, (footnote 2) which states: “93.1(5) Computing FAPI in respect of partnership — For the purpose of applying a relevant `provision in respect of a foreign affiliate [LLC2] of a taxpayer [USP] resident in Canada, if at any time the taxpayer is a partnership of which a particular corporation [Canco] resident in Canada, or a foreign affiliate of the particular corporation, is a member and if, based on the relevant assumptions, the particular corporation [Canco] and the taxpayer [USP] would be related, then (a) a non-resident corporation [USOpco] that is, at that time, a foreign affiliate of the particular corporation [Canco] is deemed to be, at that time, a foreign affiliate of the taxpayer [USP]; and (b) the taxpayer [USP] is deemed to have, at that time, a qualifying interest in respect of that foreign affiliate [USOpco] if the particular corporation [Canco] has, at that time, a qualifying interest in respect of the non-resident corporation [USOpco]. 93.1(6) Relevant provisions and assumptions — For the purposes of subsection (5), (a) the relevant provisions are… (iii) paragraphs 95(2)(a) and (g), and… (b) the relevant assumptions are that (i) the partnership is a non-resident corporation having capital stock of a single class divided into 100 issued shares that each have full voting rights, and ii) each member of the partnership (other than another partnership) owns, at any time, the proportion of the issued shares of that class that (A) the fair market value of the member's interest held, directly or indirectly through one or more partnerships, in the partnership at that time is of (B) the fair market value of all the interests in the partnership held directly by members of the partnership at that time.” ...

The relevant facts can generally be summarized as follows: In XXXXXXXXXX, XXXXXXXXXX and its subsidiaries ("XXXXXXXXXX ") applied for and received protection under the CCAA. ...

The Queen 99 DTC 5669 [SCC] and Stewart v The Queen 2002 DTC 6969 "XXXXXXXXXX " However, we have been unable to identify any comments in either of these decisions that support the Representative's position. ...

In the Macmillan-Bloedel decision, the judge stated: "... when one carefully analyzes the situation, there are, from a business and accounting view, two transactions. ...

The transactions must also be in full technical compliance with relevant provisions of the Act, including paragraph 20(1)(c) where interest expense deductions are claimed and subsections 112(1) – (2.4) if relying on inter-corporate dividend deductions. ...

$XXXXXXXXXX ÷ U.S.$XXXXXXXXXX) would have been issued. This differential likely indicates that the conversion did not occur pursuant to the terms of the Notes. ...

In the event the trust is revoked under this Section XXXXXXXXXX, the Trustee shall forthwith distribute the entire then trust estate of the trust in the following shares – XXXXXXXXXX to Mother and XXXXXXXXXX each to the Children. ...

Generally, in files where the status of XXXXXXXXXX MRPS as equity – as opposed to debt or some other type of instrument- was relevant, Rulings accepted that such MRPS would be treated as equity for purposes of the Act. ...

September 20, 2002 International Policy & Business HEADQUARTERS Management Division Income Tax Rulings Directorate Policy and Publications Unit I S. ...