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You asked us whether a T2060 is required for each former partner and whether the penalty is required to be paid by each former partner. 21(1)(a) 21(1)(b) Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ` ...

Farrell Chief of Verifications & Collections Revenue Canada, Taxation Mississauga District Taxation Office P.O. ...

Convention on the other hand, where payments in excess of the "minimum amount" are withdrawn in a year, such payments would not even fall under the definition of "pension" because the definition found in Article XVII(3) excludes: "... any payment under a retirement plan... in settlement of all future entitlements... ...

Chief Services, Public Utilities & Exempt Corporations Section Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

In addition, a review of Falconbridge on "Banking and Bills of Exchange" states on page 759 that "... a "deposit" could, depending on the contractual terms, refer to money loaned to a bank in exchange for any kind of document evidencing such indebtedness, including... bank passbooks". ...

(c) Since a partnership is by definition "... the relation that subsists between persons carrying on business in common with a view to profit" (paragraph 2 of IT-90) it is our view that the sale of assets to a corporation by the LP followed shortly thereafter by a sale of the capital shares by the LP could also be an adventure in the nature of trade. ...

According to the Canadian Alamanac & Directory 1988 Copp Clark Pitman Ltd. ...

It is our view that in situations 1, 2 & 4 above, the payments are subject to Part XIII tax under subsection 212(5) of the Act. ...

We would agree that the "right" and the "warrant" would both be considered to be "... a right to buy additional shares... ...

" would be subject to the purpose test of subsection 55(2) of the Act. ...