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12 October 1992 Income Tax Severed Letter 9230047- Loans Between Non-residents Unedited CRA Tags 80.4(2), 214(3)(a), 212(2), 15(8) RULINGS TAX SEMINAR CENTRAL REGION OCTOBER 14 & 15, 1992 Subsection 80.4(2) Question In some cases, loans between non-resident corporations can give rise to Part XIII tax. ...

Day 20th Floor, Area F (613) 957-2136 330 Queen Street Ottawa, Ontario K1A 0N5 October 20, 1992 Dear Ms Jamieson: Re: Your file No: 1835- 65 & 1835- 66 We are writing in reply to your letter of August 25, 1992, wherein you requested our views regarding the income tax implications for the reimbursement of room and board deductions, made from the training allowances paid to Radio Operations and Air Traffic Control Students during periods when they were away from the Transport Canada Training Institute (TCTI) during their paid trips home during mid- course breaks. ...

" as a result of payment of the bonus or penalty "... would have been paid or payable by the taxpayer as interest on the debt obligation for a taxation year of the taxpayer ending after that time,... ...

Saint John Shipbuilding & Dry Dock Co. Ltd. case (the "Saint John Shipbuilding case"). ...

P Co has elected under subsection 216(1) of the Income Tax Act, Canada ("Act") to be taxed in respect of its Canadian source rental income on a "net " basis for its 1982 taxation year ended December 31, 1982; 6. ...

"Fair market value" is not defined in the Act but has been defined by the courts as being: "... the highest price available in an open and unrestricted market between informed, prudent parties, acting at arm's length and under no compulsion to act, expressed in terms of money or money's worth". ...

Subsection 80(1) applies when "... a debt or other obligation of the taxpayer to pay an amount is settled or extinguished after 1971 by the payment of an amount less that the principal amount of the debt or obligation... ...

July 6, 1989 # 66 (June) 5-8243 A.B. Adler (613) 957-8962 XXX Attention: XXX July 6, 1989 Dear Sirs: This is in reply to your letter of June 15, 1989 in which you raised two questions with respect to the application of subparagraph 108(2)(b)(iii) of the Income Tax Act (the "Act") to a proposed unit trust. ...

July 18, 1989 # 296 3-2541 W.C. Harding (613) 957-3499 XXX July 18, 1989 Dear Sirs: Re: Request for Advance Income Tax Ruling XXX This is in reply to your letter couriered to us on June 30, 1989 wherein you requested the above-noted ruling. ...

You might also wish to refer to the following tax cases that comment on the type of situation to which either paragraph 18(1)(e) or subsection 245(1) could apply: Day & Ross Ltd. v. ...