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12 July 1989 Ministerial Letter 74058 F- Employee Savings and Share Purchase Plan Unedited CRA Tags 5(1), 7, 9, 67, 104, 105, 106, 107, 108, 248(1) employee benefit plan, 248(1) retirement compensation arrangement 19(1) File No. 7-4058   F. Francis   (613) 957-3496 July 12, 1989 Dear Sirs: Re:  24(1) Employee Savings & Share Purchase Plan (the ""Plan") This is in reply to your letter of March 27, 1989, to our Registration Division wherein you requested our opinion in respect of proposed amendments to the P;an which will be effective on July 1, 1989. ...

25 July 1990 Ministerial Letter 74608 F- Minimum Tax Carry Over and Non-residents Unedited CRA Tags n/a   July 25, 1990 Non-Resident Taxation Division Rulings Directorate   M.P. ... Hillier 957-2125 Director   7-4608 SUBJECT: Minimum Tax Carry-Over and Non-Residents File HDB 8788-1 This is in reply to your memorandum of December 20, 1989 regarding the application of the minimum tax carry-over provisions to reduce Part I tax pertaining to a non-resident. ...

(B)       AS IT APPEARED THAT THE BUSINESS WOULD BE SUCCESSFUL AT THE OUTSET, HE DECIDED THAT HIS TWO YOUNGER BROTHER, B AND C, WOULD HELP HIM TO RUN THE BUSINESS. (C)       IN AUGUST, 1988 A, B, AND C TRANSFERRED THE BUSINESS, OTHER THAN THE BUILDING WHICH WAS STILL OWNED BY A, INTO X CO, A NEW CORPORATION.  ... (E)       IN JULY, 1989, A WAS DIAGNOSED AS SUFFERING FROM A TERMINAL ILLNESS AND IN JULY OF 1990, HE DIED.  ...

21 February 1990 Ministerial Letter 74658 F- Donation of Debt Unedited CRA Tags n/a   February 21, 1990 Charities Division Business and General Division G.J. ... Thornley   957-2101   File No. 7-4658 Subject: Donation of Debt This is in reply to your T2003 of January 7, 1990, with attached article entitled "Donations of LDC debt by banks to charities". ...

2 February 1990 Ministerial Letter 00258 F- Employment Benefits Unedited CRA Tags 62, 6(1)(b)   February 2, 1990 To- File From- A. Humenuk   957-2135   File No. 0-0258 Subject:  Employment Benefits We have reviewed the attached memorandum of December 19, 1988, from Michael 1.  ...

Eventually, the taxpayer locates a purchaser and sells all the shares of Newco, reporting the proceeds as a capital gain.       ... "      Although this article relates to GAAR, it is our view that  these comments are equally relevant for purposes of subsection 55(2) of the Act and should be included in the Participants Package. 3.      ... "      Similar amendments may also be needed to the points mentioned under the heading "Treatment of Liabilities" on page 67 of the Lesson Plan. 22.      ...

General Comments 1.      On page 11 of the final draft, the last part of the second "bullet" should read:      "...active business carried on by you or the members of the partnership, or an interest in a partnership where all or substantially all of the partnership's assets were used in an active business carried on by the members of the partnership." 2.      On page 16 of the final draft, the first sentence of the third paragraph under the heading "Employees' stock options" might be clearer if it read as follows:      "Generally the taxable benefit is included in your income in the year you acquire the shares through the option.  ... " 3.      On page 62 of the final draft, where the rules in subsection 44(5) of the Act are discussed, the grammatical structure is somewhat awkward.  ...

However, the comments under all of these paragraphs are somewhat incomplete since the key phrase "in respect of the production or reproduction" in subparagraph 212(1)(d)(vi) is missing in each of these paragraphs.       ... (iii)     payments made by a person resident in Canada to a           non-resident under a license agreement whereby the          non-resident owner of a computer program grants rights to such a person to produce or reproduce the program in Canada for distribution to other persons.      The payments described in (i) and (ii) above are subject to Part XIII tax by virtue of subparagraph 212(1)(d)(i) of the Act and they do not fall under the exemption provided under subparagraph 212(1)(d)(vi) of the Act.       ...

A's habitation.      Whether the dwelling can be said to be used for Mr. ... The legal definition of habitation does not preclude the possibility of two places of habitation.       ... A, a majority shareholder of the corporation, in order for the loan to be a loan described in subparagraph 15(2)(a)(ii) of the Act.       ...

Harding   (613) 957-3499 Attention:  John Pruyn   File No. 7-3848 SUBJECT:  Withdrawal form a U.S.A. ... Please refer to Interpretation Bulletin 280 and Information Circular 77-1R3, para. 59; and 2.       ... For this period, the findings in the case of Hogg would have prevailed and amounts which vested in the beneficiary should have been taxed to her.       ...