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9 January 1996 Ministerial Correspondence 952924A- CASH CONCENTRATION ACCOUNTS & PART I.3-- summary under Subsection 181.2(4) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(4) Inconclusive discussion of group concentration accounts. ...

2004 Ruling 2004-0099651R3- Migration to Canada / PUC Reduction-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) Opinion that a non-resident corporation would become resident in Canada upon replacing its board with a new board a majority of whom resided in Canada and which conducted meetings in Canada. ...

"Partial Payment Rec'd for GIC & Accrued Interest")-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) "Unless there is any indication to the contrary, payments received in partial payment of debt (in this case, a GIC) should be applied first to interest rather than to principal. ...

15 January 2007 Internal T.I. 2006-0216801I7- Redemption of US $ Denominated Shares-- summary under Subsection 84(3) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(3) MacMillan Bloedel to be followed Confirmation of a previous position that in light of the MacMillan Bloedel decision, CRA intends to assess any redemption of foreign-currency-denominated redeemable and retractable preferred shares on the basis that s. 39(2) applies to the issuer corporation. ...

2006 Ruling 2004-0106101R3- Class of German Arrangement & Treaty Benefits-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Ruling that a German open-end real estate fund would be treated as a resident of Germany for purposes of Article 4 of the German Treaty. ...

7 March 1997 External T.I. 9704665- NASDAQ & OTC BULLETIN BOARD-- summary under Regulation 3201 Summary Under Tax Topics- Income Tax Regulations- Regulation 3201 The Over-the-Counter Bulletin Board market in the United States is not a prescribed stock exchange, notwithstanding the ownership of that market by the National Association of Securities Dealers, Inc. ...

17 September 1997 External T.I. 9721415- INTERACTION OF SUBSECTION 55(2) & DIVIDEND REFUNDS-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) The fact that a dividend refund has been received by the payor of a dividend is not normally relevant to consideration of the following expression: "that is not refunded as a consequence of the payment of a dividend to a corporation where the payment is part of the series of transactions or events". ...

6 July 1998 External T.I. 9811115- ATTRIBUTION & GENUINE LOAN-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) Discussion of when a loan of money by a parent to a trust will qualify as a "genuine loan" so that s. 75(2) does not apply. ...

8 June 1998 External T.I. 9806285- RRSP- FOREIGN PROPERTY & REINVESTED EARNINGS-- summary under Subsection 206(2) Summary Under Tax Topics- Income Tax Act- Section 206- Subsection 206(2) The cost amount of units of a mutual fund trust that is foreign property include the amount of dividend distributions that have been reinvested in additional units. ...

23 March 1994 Administrative Letter 9332416 F- Japan Inhabitant's Tax — Income or Profits Tax-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax The municipal inhabitant's tax imposed by Japan is an income tax with the exception of any per capita tax included in that tax. ...