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Yours truly, for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch Document Disclosed Pursuant to the Access to Information Act Document Divulgué en vertu de la loi sur l'accès à l'informationLANGIND E DOCNUM AC59207 REPLACES TYPEKEY R AUTHORDV LEGS AUTHOR PLEE DESCKEY 5 RATEKEY 1 REFDATE 900205 ETADYEAR ETADSORT ADMINACC LEGS ACCESSLV LEGS99 SUBJECT Loss on disposition of a property which is a loan SECTION ITA-18(13) SECTION SECTION SECTION SECTION $$$$ 5- 9207 19(1) Peter Lee (613) 957-2745 February 5, 1990 Dear Sirs: Re: Subsection 18(13) of the Income Tax Act (the "Act") Loss on Disposition of a Property Which is a Loan We are writing in reply to your letter of December 4, 1989, wherein you requested our opinion as to whether subsection 18(13) of the Act would deny a loss on disposition of a property which is a loan, only to the extent that the loss exceeds any paragraph 20(1)(1) reserve previously claimed. ...

It is intended that Bco transfer the following properties to Aco under a reorganization that would be carried out pursuant to paragraph 55(3)(b) of the Act: Fair Market Liabilities Allocated Tax Cost Value Specific Non-Specific Property 1 $ 1 2,000 1,000 300 Property 2 2,000 4,000 600 The reorganization will be carried out on a "net equity basis", whereby each of the properties will be transferred net of its respective liabilities. ...

Olympia floor & Wall Tile v. M.N.R. [[1970] C.T.C. 99] 70 DTC 6085 24(1) 23 We see no competition between equally applicable provisions of the law in the other two cases. ...

Liebig & Co. v. Leading Investments Ltd. (1980) (25 D.L.R. (4th) 161) as support for the position that a real estate commission is not receiveable under paragraph 12(1)(b) with respect to an unclosed sale. ...

Gain 200,000- less Tax @ 485 (96,000)- Net Increase in Safe Income $204,000 204,000 Safe Income on Hand immediately after disposition of SRTC property $5,404,000 ...

" In ascertaining the residual value, one would determine what an arm's length person would pay today in order to have the capital of the trust "x" years from now. ...

> 90%) of his duties of employment in Country P 6. Individual Y is in Country P to carry out the following activities: (a) To conclude a joint venture contract with a resident of Country P. ...

We note that the Federal Court of Appeal [[1992] 2 C.T.C. 379] (92 DTC 6473) did not deal with whether the stock option benefit was "remuneration " for purposes of the Canada-U.K. ...

Subsection 118.6(2) of the Act reads, in part, as follows: Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information "For the purpose of computing the tax payable under this Part by an individual for a taxation year, there may be deducted an amount determined by the formula A x $60 x B (...)" ...

Subparagraph (iv) goes on to read "... and all or substantially all the use of which is in conjunction with that property. ...