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22 October 1990 Administrative Letter 902306 F- Determination of Paid-up Capital Unedited CRA Tags 83(1), 84.1, 89(1) paid-up capital, 183.1, 183.2(1), 186(4)   October 22, 1990 SAINT JOHN DISTRICT OFFICE Rulings Directorate Mr. ... In this regard we offer the following comments: The provisions of section 84.1 of the Act apply when an individual shareholder resident in Canada disposes of his shares of a Canadian corporation (the subject shares) to another corporation (the purchaser corporation) in a non arm's length transaction and following which the subject corporation is connected with the purchaser corporation within the meaning of subsection 186(4) of the Act 24(1) Paragraph 84.1(1)(a) of the Act applies to the determination of the paid-up capital of the 24(1) as follows: (A -  B)  X      C     A A = PUC increase in respect of all shares of the purchaser corporation. B = Greater of: (i)     PUC of subject shares (ii)     ACB of subject shares- as adjusted by paragraphs 84.1(2) (a) and (a.1) C = PUC increase in respect of particular class of shares of the purchaser. ...

27 August 1990 Administrative Letter 901776 F- Non-profit Organizations Unedited CRA Tags 149(1)(l)   901776   Bill Guglich   (613) 957-2102     EACC 9257 Attention: 19(1) August 27, 1990 Dear Sirs: This is in reply to your letter of August 13, 1990 concerning the impact of the Goods and Services Tax (GST) Legislation on the tax status of a non-profit organization (NPO) under paragraph 149(1)(1) of the Income Tax Act (the Act). ...

26 November 1990 Administrative Letter 900146 F- Inventoriable Tooling Costs Unedited CRA Tags n/a   November 26, 1990 WINDSOR DISTRICT OFFICE RULINGS DIRECTORATE Basic Files C. Tremblay   (613) 952-1361 Attention: R. Galbraith   900146 SUBJECT:  Inventoriable Tooling Costs  24(1) This is in reply to your memorandum received on December 4, 1989, concerning 24(1)     23 The relevant facts are as follows: 24(1) Taxpayer's Position 24(1) Our Comments Whether an asset is capital or inventory, in either case, it must be owned by the taxpayer.  24(1)  Generally, the date on which a disposition is considered to have occurred would be the effective date of the transaction as agreed by the parties, unless a contrary intention could be shown; the word "disposition" is used at its widest possible meaning in the capital cost allowance provisions of the Income Tax Act. ... M.N.R. 60 DTC 1183, Judge Thurlow, for the Exchequer Court, expressed his understanding of this criteria at page 1185 as follows:      ... the term power in general being associated in legal usage with the description of an authority in respect to property or an interest in property which does not itself belong to the person holding the power. ...

.'S Unedited CRA Tags Treaty UK Article 27A     921078   Jim Wilson   957-2123 May 27, 1992 International Tax ProgramsRulings DirectorateC.G. ...

5 May 1992 Administrative Letter 9212746 F- RRSP Promotion Unedited CRA Tags 146(2)(c.4)     7-921274   P. Spice   957-8953 May 5, 1992 Registered Plans DivisionFinancial Industries DivisionMrs. ...

29 March 1991 Administrative Letter 903386 F- Interest on Money in Fund Unedited CRA Tags 5(1), 56(2), 12(1)(c)    File No. 903386                                                   R.B. Day                                                   (613) 957-2136                 March 29, 1991 Re: 24(1) We are writing in reply to your letter of November 16, 1990. wherein you requested an advance income tax ruling on behalf of 24(1).  ... Interest on the amounts in the Fund would be taxable in the hands of the employee pursuant to paragraph 12(1)(c) of the Act in the year paid or credited to the Fund.      ...

22 March 1989 Administrative Letter 74537- Régime de prestations aux employés Unedited CRA Tags n/a   March 22, 1989         BUREAU DE DISTRICT                  BUREAU PRINCIPAL       DE SHERBROOKE                       Section des services       Chef de la vérification                bilingues                                           Vicki Plant                                           (613) 957-4796   FILE 7-4537OBJET: Régime de prestations aux employésLa présente est en réponse à votre note de service du 20 novembre 1989 dans laquelle vous demandez nos commentaires, afin de déterminer s'il y a des incidences fiscales autres que celles delà établies par les contribuables. ...

17 February 1992 Administrative Letter 9201576 F- Dental Plan PHSP 24(1) Section 6(1)(a)(i) Unedited CRA Tags 248(1) Private health service plan   February 17, 1992 Audit Technical Support Division Business and General K.R. Warren   Division Acting Director R.B. Day   (613) 957-2136   920157 24(1) We are writing in reply to your memorandum of January 14, 1992, wherein you requested our views as to whether the 24(1) "Direct Reimbursement Dental Plan" (DRDP) would qualify as a "private health services plan" (PHSP) as defined in subsection 248(1). ... In order for a particular DRDP to qualify as a PHSP, as defined, the plan implemented by an employer on behalf of its employees must be in the nature of insurance and must contain the following elements as set out in paragraph 3 of IT-339R2: (i)     an undertaking of one person,  (ii)     to indemnify another person, (iii)      for an agreed consideration, (iv)      from a loss or liability in respect of an event, (v)      the happening of which is uncertain. ...

B)        Income Tax Implications      While we are unable to provide a discussion on all of the income tax implications of renting a houseboat, we can provide a few general comments on this subject as indicated below.       ... Where a corporation was incorporated to earn income by carrying on a business, there is a general presumption that profits arising from its activities are derived from a business.         ... The determination as to whether an entity is carrying on a business is relevant for the purposes of determining if that entity can qualify for one of the exceptions to the CCA restriction discussed below.       ...

Francis   957-3496 Attention:  B. Bertrand   File No. 7-4046 Subject: 24(1) Deferred Profit Sharing Plan ("DPSP") This is in reply to your memorandum of March 28, 1989, wherein you requested our opinion in respect of the following situation:-     24(1)-      Subsection 147(9.1) of the Income Tax Act (the "Act") provides that for taxation years commencing after 1981, no deduction can be made in computing the income of the employer for a taxation year in respect of an amount paid by him to a DPSP in respect of a beneficiary described in paragraph 147(2)(k. of the Act.  Contributions to the DPSP appear to have ceased in accordance with subsection 147(9.1) of the Act.--      24(1) The amounts withdrawn by the company are as follows: 24(1) 24(1) You request us to advise you of the tax consequences to the shareholders and the Company. Pursuant to subsection 147(15) of the Act, the following rules will apply to the revoked plan-      the revoked plan is deemed not to be a DPSP or an employee profit sharing plan as of September 30, 1984.-      the trust is taxable on its taxable income for its 1984 and subsequent taxation year.-      the funds withdrawn by the Company will be included in its income in the year of withdrawal. ...