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12 June 1990 Administrative Letter 59716 F- Investment Contract Acquired Before 1990 Unedited CRA Tags 12(4), 12(11)(a), 78(1)(b) 24(1) File No. 5-9716   Kevin J. ... The application of the amendment to paragraph 12(11)(a) of the Act contained in subsection 4(4) of Bill C-28, is described in subsection 4(7) of Bill c-28 as follows:      Subsection (4) is applicable to the 1985 and subsequent taxation years, except that, in applying paragraph 12(11)a) of the said Act, as enacted by subsection (4), in respect of debt obligations acquired before 1990, that paragraph shall be read as follows: (a)      "investment contract", in relation to a taxpayer, means any debt obligation (other than a salary deferral arrangement, an income bond, an income debenture, a small business development bond, a small business bond, an obligation in respect of  which the taxpayer has, at periodic intervals of less than 3 years, included, in computing the taxpayer's income throughout the period in which the taxpayer held an interest in the obligation, the income accrued thereon for such intervals, or a prescribed contract); Where paragraph 78(1)(b) of the Act has applied to an obligation acquired by a taxpayer in 1980 so that accrued interest has been included in income on January 1, 1983 and each subsequent year in computing the taxpayer's income, it is our opinion that the proposed form of subsection 12(4) of the Act, if enacted, would not apply to that obligation.  In the foregoing circumstances, the exception in the above-noted amended definition of investment contract would be met, i.e. the taxpayer's obligation would be      ...an obligation in respect of which the taxpayer has, at periodic intervals of less than 3 years, included, in computing the taxpayer's income throughout the period in which the taxpayer held an interest in the obligation, the income accrued thereon for such intervals,... ...

6 June 1990 Administrative Letter 59386 F- Canada-Italy Income Tax Treaty- Partnership Interest Unedited CRA Tags 115(1)(b)(iii), 2(3)(c), 212.1, 116 24(1) File No. 5-9386   G. ... In Dicey and Morris on The Conflict of Laws, 10th edition, Volume 2 at page 522 the authors state:      "The distinction between movables and immovables is not co- extensive with the distinction between realty and personality." At page 525 the authors go on to state:      "There is no clear English authority on whether a partner's interest in partnership land is an interest in a movable or in an immovable. ...

L'adresse et le numéro de téléphone apparaissent à la première page de la circulaire ci-incluse.       ... Vu qu'un organisme de charité enregistré est exempté d'impôt, il n'y aurait aucun impôt payable sur le revenu gagné pendant la période où il était enregistré selon l'alinéa 149(1)f) de la Loi.       ... Chaque organisme de charité enregistré est tenu, chaque année, d'avoir dépensé son "contingent des versements", au sens de cette expression définie à l'alinéa 149.1(1)e) de la Loi et expliquée en détail dans un guide fourni pour aider les organismes à remplir la déclaration annuelle de renseignements.       ...

Opco is owned 100% by Holdco. 4.     Opco carries on a business in its own name and also holds investments in Subco 1 and Subco 2. 5.      ... The assets of Opco and their fair market value at the present time are as follows: Assets used in active business $950,000 Shares of Subco 1 300,000 Shares of Subco 2 450,000 Term Deposits 350,000   $2,050,000 6.      ... Subco 1 carries on an active business and all of its assets are used in the active business at the present time. 7.      ...

Holloway / 613-957-2104 ...

23 December 1991 Administrative Letter 9133646 F- Disability Insurance Unedited CRA Tags ITAR 19, 6(1)(f) Disability Insurance  —  Application of ITAR 19  We are writing with respect to your memorandum of December 5, 1991, and the enquiry from Scarborough D.O., wherein our views were requested as to whether or not the benefits the taxpayer will receive in 24(1) (the company) would be taxable in the taxpayer's hands. ...

21 November 1991 Administrative Letter 911866 F- Goods and Services Tax Rebate- Employees and Partners Unedited CRA Tags 6(8) Re: Goods and Services Tax Rebate Employees & Partners This is in reply to your memorandum dated July 9, 1991 wherein you requested our opinion concerning the application of several amendments to the Income Tax Act (the "Act") as part of Bill C-62. ...

2 May 1990 Administrative Letter 74756 F- Nova Scotia Tax Reduction for New Small Business Corporations Unedited CRA Tags 12(1)(x)   May 2, 1990 Halifax District Office Head Office Audit Review Section Specialty Rulings   Dave Turner Kevin McGuigan (613) 957-2094 SUBJECT: Nova Scotia Tax Reduction for New Small Business Corporations We are writing in reply to your memorandum of February 21, 1990, concerning whether the Nova Scotia tax reduction for new small business corporations (the "Reduction") should be brought into the taxpayer's income under paragraph 12(1)(x) of the Income Tax Act (the "Act"). ... Our Comments In our opinion, the Reduction should not be added back to the income of the taxpayer for the following reasons: 1)     Paragraph 12(1)(x) of the Act applies only to amounts received by a taxpayer in the year, in the course of earning income from a business or property.  ... For example, the following would be considered to be "inducements" and have to be added back to income under paragraph 12(1)(x) of the Act: a)     The Federal small business deduction, as it is an "inducement" to start a small business in Canada. b)     The manufacturing and processing profits deduction, as it is an "inducement" to start a manufacturing and processing business in Canada. c)     The difference between the higher provincial rates large corporations and the lower rates on income subject to the small business deduction, as the difference is an "inducement" to operate a small business.       ...

A holds 100% of the shares of A Limited, an NRO. 2.     A Limited was incorporated in Canada after 1971. 3.      ... The holdings of the public corporations are less than 25% of the public corporations' stock. b) Our Opinion 1.      ... A became a resident of Canada. 2.     Subsection 48(3) of the Act will not apply to A Limited when Mr. ...

OUR OPINION 1.     There is no specific definition of the word "bonus" in the Act or in the Regulations. ... " 2.     In the French version of the Act, the Parliament used the term "gratification" for bonus. ... " 3.     According to the Bulletin de terminologie comptable, a document published by the Ordre des comptables agréés du Quèbec, the word "bonus" in English contains three notions: a)     an amount paid for a superior performance, b)     an amount paid in compensation for dangerous work conditions, c)     a reward without any reference to the performance of the employee. ...