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Pour la directrice Division des services bilingues et des industries d'exploitation des ressources Direction des décisions ` ...

18 May 1990 Income Tax Severed Letter RRRR202 F- Report des pertes après l'acquisition de contrôle Unedited CRA Tags 88(1.1)(e), 111(5), 249(4) TO BUREAU DE DISTRICT DE MONTRÉAL FROM BUREAU PRINCIPAL ' DE Section des services bilingues Rémi St-Louis G. ...

You have requested that we confirm that the content of the Plan complies with the provisions of section 6801 of the Income Tax Regulations (the “ Regulations”). ...

Paragraph 118.2(2)(l.2) states, in part, that "... a medical expense of an individual is an amount paid... ...

In your view, a chartered bank will grant a loan for reasons which are entirely related to the economic security of the lender and in no circumstances will non-recourse borrowings be provided "... for the purpose of... ...

Under 13(27)(c) & (28)(d) a t/p is considered to have acquired property immediately before disposition if none of the other times occur earlier. ...

Some important factors to be considered in making such a determination include: • location of the business office- where the books and records are kept- where business transactions with customers and suppliers are arranged- where employees report for work or are paid from- where inventory is ordered and often maintained. ...

Because such income is taxed under Subdivision d of Division B of the Act which is entitled “Other Sources of Income”, rather than under Subdivision b of Division B which is entitled “Income or loss from a business or property”, you suggest that such income would not be “ income from property” for the purposes of various provisions of the Act such as sections 74.1, 110.6 and 207.5. ...

In our view, this position ignores the provisions of paragraph 87(2)(b) and, in particular, the following clause: ”... the property [the inventory] so included shall be deemed to have been acquired by the new corporation at the commencement of its first taxation year for an amount determined in accordance with section 10 thereof for the purpose of computing the income of the predecessor corporation for its last taxation year...” ...

" In addition to the use of the word ancillary, subparagraph (iv) goes on to read "... and all or substantially all the use of which is in conjunction with that property. ...