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Former IT-436 contains comments in paragraphs 9 & 10 which, although not included in IT-436R due to the introduction of new 5 year time limit restrictions, are still considered relevant in some situations. ...

Yours truly, Chief Leasing & Financing Financial Industries Division Rulings Directorate ...

Yours truly, Section Chief Leasing & Financing Section Financial Industries Division Rulings Directorate Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...

The Department made the following comments, which are still applicable to date, on this issue: "... ...

Carkner, of Client Assistance Directorate and further to a telephone conversation (Lisa Loyko Baker / Claude Tremblay) of March 17, 1992, regarding account holders, investment certificate holders and shareholders of XXX We were advised that all individual investors have recently received T5 slips. ...

We also refer to Olympia & York Developments Ltd. v The Queen, [[1980] C.T.C. 265] 80 DTC 6184(FCTB), at p. 6193. ...

In the 1988 Revenue Canada Round Table, we set out the following position: " Where a public corporation makes a bona fide loan to a shareholder qua employee rather than qua shareholder, on the same conditions as to other employees who are not shareholders, it is Revenue Canada's policy to treat it as a loan to an employee rather than to a shareholder (Ref. ...

XXX = 89%- see paragraph's 5 and 17 of Interpretation Bulletin IT- 171R) and therefore former section 118.91 would have denied a nonrefundable tax credit otherwise allowable under section 118.1 except where the non-refundable tax credit otherwise permitted may reasonably be considered wholly applicable to the individual for the period or periods in the year throughout which he is resident in Canada, employed in Canada or carrying on business in Canada. ...

Phil Keirstead Business & General Business Enquiries Division Audit Review (148-1-6) H. ...

Although subsection 96(1) of the Act sets out rules for the computation of a partner's income "... as if the partnership were another person.. ...