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Le plafond de l'exonération pour gains en capital reflète le taux d'inclusion du gain en capital pour une année particulieère sur 100 000 $ de gains en capital. ...

Gauvreau Chief Resource Industries Section Bilingual Services & Resource Industries Division Rulings Directorate Enclosure ...

All other payments made out of an RRSP or RRIF would be subject to 25 % withholding tax in accordance with paragraphs 212(1)(1) and (q) of the Income Tax Act. ...

A monthly administration fee of a fund would not appear to be deductible to that taxpayer under that paragraph either as it is not paid "... for services in respect of the administration or management of shares or securities of, the taxpayer", since it is the fund's shares and securities that are being managed or administered. ...

The restatement of the opening balance of the reserve, at least for financial statement purposes, seems to have been a requirement of regulations or other rules related to the Banks & Banking Law Revision Rules, 1980 and applicable effective the first day of the Bank's 1982 taxation year from the Toronto District Office's rather brief explanation of the matter in their memorandum of January 31, 1985 to your section. ...

"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 8(5) reads in part as follows: "... with respect to dispositions of property occurring after June 17, 1987, otherwise than pursuant to the terms of an obligation entered into in writing before June 18, 1987, and before paragraph 14(5)(a) as enacted by subsection (2) comes into effect... ...

This followed the reasoning in Tory Estate 71 DTC 5271 in which at page 5278 it was stated that property is transferred or distributed to a person in the context of subsection 70(3) of the Act "... only when such transfer or distribution has been made to him "qua beneficiary" and not to the extent that he has acquired it as a purchaser for value. ...

15 August 1990 Income Tax Severed Letter ACC9308- Qualification as a Benevolent or Fraternal Society HEAD OFFICE Rulings Directorate Appeals & Referrals Division C. ...

Yours truly, ORIGINAL SIGNED BY for Director Small Business & General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...