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16 November 1990 Ministerial Letter F3868 F- Associated Corporations- Meaning of "Accrued and Unpaid Dividends" and "Unpaid Dividends" Unedited CRA Tags 191(4), 256(1.1)   November 16, 1990 Rulings Directorate Current Amendments and Director General Regulations Division   W.R. ... Ton-That 957-2068   F-3868 "Accrued and Unpaid Dividends"- 191(4) and "Unpaid Dividends"- 256(1.1) This is in reply to your memo of November 7, 1990 concerning the above terms used in the respective subsections of the Income Tax Act and whether in policy terms they are intended to have the same meaning. ... D'AurelioDirectorCurrent Amendments and Regulations Division c.c.      ...

23 February 1990 Ministerial Letter 59468 F- Group Life Plan Distribution of Surplus Unedited CRA Tags n/a   February 23, 1990 Edmonton District Office Business and General E.J. ... Jones   (613) 957-2104   File No. 5-9468 Re: 24(1) Group Life Plan (the "Plan") Distribution of Surplus We are forwarding the attached correspondence for your reply and any other action you may feel is appropriate as we feel you are in a better position to respond to the 24(1) concerns. ... Should you require any assistance with respect to any interpretive problems that you may have with respect to this issue, please contact Duncan Jones at 613-957-2104. for DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch c.c.      ...

30 April 1990 Ministerial Letter 900498- Remise d'impôt Unedited CRA Tags n/a   Le 30 avril 1990 A- BUREAU DE DISTRICT DE- BUREAU PRINCIPAL  DE MONTREAL Division des services   bilingues Céline Renaud Anne LeBlanc Affaires Publiques (613) 957-4363 OBJET:  19(1) La présente note de service fait suite à votre note aller-retour du 20 avril 1990 concernant le contribuable précité. ... DirectriceDivision des services bilingues et des industries d'exploitation des ressources Direction des décisions c.c.:      M. ...

16 August 1989 Ministerial Letter 58108- Frais médicaux Unedited CRA Tags 118.2(2) 19(1) File No. 5-8108   V. ... 2.     Est-ce que un "conseiller" en produits naturels, reconnu par une compagnie, ou interviennent des bio-chimistes et où la formation est continue, peut être reconnu comme naturopathe? ... Il faut que les deux conditions soient satisfaites pour que les ordonnances soient admissibles. 2.      ...

This exception is an administrative concession by the Department and will not be available unless all of the six conditions set out by the Department, as restated hereunder, are satisfied. 1)     The corporation's only objective is the holding of property for the personal use or enjoyment of the shareholder. 2)     The shares of the corporation are held be an individual or person (other than a corporation) related to the individual. 3)     The only transactions of the corporation relate to its objective of holding property for the personal use or enjoyment of the shareholder. 4)     The shareholder would be charged with all the operating expenses by the corporation, with the result that the corporation would show no profit or loss with respect to the property on any of its returns. 5)     The corporation acquired the property with funds provided solely by the shareholder and not by virtue of his holdings or that of a related person in any other corporation. 6)     The property must be acquired by the corporation on a fully taxable basis (that is, without the use of any of the rollover provisions of the Act). ...

8 February 1990 Ministerial Letter 59508 F- Deferred Salary Leave Plan Unedited CRA Tags 6801 19(1) File No. 5-9508   A.B. ... It is our position that (i)       UI premiums are to be based on the employee's gross salary before deferrals during the period of deferral and no premiums are to be withheld from the deferred amounts when paid to the employee during the leave period. (ii)      CPP premiums are to be based on the employee's salary net of the deferred amounts during the period of deferral and on the deferred amounts during the period of deferral and on the deferred amounts when paid to the employee during the leave period.  ...

In particular these notes explain that:      "paragraph (21)(c) provides that for the purposes of this rule separate lots that result from the subdivision of a parcel of land are to be regarded as "a property" rather than separate properties. ... "-         A disposition of undivided interests for income tax purposes will not occur "...when a property is subdivided and distributed (in whole or in part) between its owners in the course of a partition in such a way that each owner preserves a share of the fair market value of the property- a share that bears the same proportion to the fair market value of all the shares in the property, as the fair market value of that owner's undivided interest in the property bears to the fair market value of all the undivided interests in the property immediately before the partition."-         "When this exception applies, the rules in subsection (20) are not applicable and the new interest that each owner has pursuant to the partition is deemed to be a continuation of that owner's undivided interest such that the tax values and characteristics (cost, undepreciated capital cost, status as inventory or capital property, etc.) of the previous interest flow to the new interest. ...

Given the above, our comments on the above three hypothetical arrangements are as follows: A.      ... B.      With respect to the type of arrangement described above in situation 2, a determination as to whether or not such an arrangement is an RCA can be made only after considering all relevant facts.  ... C.      The determination of whether or not an arrangement of the type described above in situation 3 is an RCA can be made only after a review of the facts relevant to a particular case.  ...

17 October 1989 Ministerial Letter 58268 F- Associated Corporation Rules Unedited CRA Tags 256(3), 256(6), 256(1)(a) 19(1) File No. 5-8268   Firoz Ahmed   Tel. (613) 957-2092 October 17, 1989 Dear Sirs: Re:  Subsections 256(3) and (6) of Income Tax Act (the "Act") This is in reply to your letter of June 21, 1989 in which you asked for our opinion concerning the application of the provisions of subsections 256(3) and (6) of the Act in the hypothetical situation described below: A corporation (the "Lender") provides funds to a second corporation (the "Debtor") by way of a secured term loan on commercial terms repayable over a period of-three to seven years, depending on the nature of the Debtor.  ... In order for subsection 256(6) of the Act to apply, both of the following conditions must be satisfied: (a)      there must be in effect an enforceable arrangement under which, upon the satisfaction of a condition or the happening of an event that it is reasonable to expect will be satisfied or happen, control of the corporation will pass from the controller to a person or group of persons dealing at arm's length with the controller; and (b)      the controller must hold control solely for the purpose of safeguarding his rights or interests in respect of debt or shares described in subparagraphs 256(6)(b)(i) or (ii) of the Act. In the situation described above, it will be a question of fact at any particular time whether: (a)      it is reasonable to expect that the loan from the Debtor to the Lender will be repaid; and (b)      the Lender holds control of the second corporation solely for the purpose of safeguarding its rights or interests in respect of the loan. ...

DM'S OFFICE (2) DM # 22992 ASSOCIATE DEPUTY MINISTER (1) ADM # 960117 ADM'S OFFICE (3) PENDING RETURN TO I.T. RULINGS & INTERPRETATIONS 15TH FLOOR, ALBION TOWER Le 26 janvier 1996 XXXXXXXXXX Monsieur le Juge, La présente fait suite à votre lettre du 3 janvier 1996 par laquelle vous me demandez des informations quant à la possibilité, pour un juge de nomination fédérale, de reporter l'impôt sur le revenu qu'il a tiré de l'exercice de sa profession avant sa nomination comme juge en 1995. ...