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18 January 1990 Ministerial Letter 74598 F- Support and Custody Agreement Unedited CRA Tags 60(b), 60(c), 60(c.1), 56(1)(c.1)   January 18, 1990 ST. CATHARINES DISTRICT OFFICE Specialty Rulings   Directorate D. Doney J.D. ... Roy10th Floor123 Slater Street c.c.     Provincial and InternationalRelations Division ...

You have asked whether it would be possible for the individuals in question to continue to receive their disability benefits tax-free.       ... Alternatively, you have asked whether the Department would accept a lump sum payment from the Employer in lieu of future payments to be received from the employees on account of their tax for the year(s) of receipt of the annuity payments.       ... As a third alternative, you ask whether it would be possible for the Employer to increase the disabled employee's benefit by 15% in order that the employee receive the same net benefit from the pension fund as received previously under the LTD Plan.       ...

Laporte A/Chief Maureen Shea-DesRosierss   (613) 957-8953 Attention: D. ... COMMENT We have discussed the above arrangement with the Department of Finance and they concur with our conclusions as follows:-      the arrangement described above would be an RCA as defined in subsection 248(1) of the Act and therefore the corporation would be required to withhold the refundable tax from any contributions made to the Director, ESA.-     payments from the Director, ESA, to an individual under the terms of the ESA would be considered a payment from an RCA to be included in income pursuant to paragraph 56(1)(x) of the Act.-      payments from the Director, ESA, to the corporation under the terms of the ESA would be taxable to the corporation pursuant to paragraph 12(1)(n.3) of the Act.-     payments received by an individual would be considered to be retiring allowances out of an RCA for the purposes of paragraph 60(j.1) and would be eligible for a roll-over to an RRSP.-     the amount of interest paid to an individual by the company would be a retiring allowance under paragraph 56(1)(a) and would be eligible for an RRSP roll-over under 60(j.1). 21(1)(b) We trust the above comments will be of assistance to you. ChiefDeferred Income Plans & Trusts SectionFinancial Industries DivisionRulings Directorate ...

Facts 24(1) 24(1) On the basis of these facts you have asked: 1.     Is the liability payment taxable? 2.     Is it eligible for a direct "roll-over" to an RRSP in the same tax sheltered manner as a pension fund transfer or return of pension contributions? ... That definition reads:      "Retiring allowance".- "retiring allowance" means an amount (other than a superannuation or pension benefit or an amount received as a consequence of the death of an employee) received      (a)  upon or after retirement of a taxpayer from an office or employment in recognition of his long service, or      (b)  in respect of a loss of an office or employment of a taxpayer, whether or not received as, on account or in lieu of payment of, damages or pursuant to an order or judgment of a competent tribunal.       ...

Situation I (a)     Mr. A and Mrs. A are married; (b)     In 1975, Mr. ... Situation II (a)     Mr. A and Mrs. A. are married; (b)     In 1975, Mr. ... A's name; (e)     In 1989, the ownership of the two properties was changed back to joint tenancy; and (f)     Subsection 73(1) applied to each of the properties. ...

This amount would represent a substantial claim against the company's asset. 3.      ... B are not related persons as defined in subsection 251(2) of the Act. 4.      ... B have acquired the necessary number of shares to control Holdco. 2.      ...

31 August 1989 Ministerial Letter 57778 F- Canada–Israel Income Tax Convention Unedited CRA Tags 116 19(1) File No. 5-7778   D.Y. ... The hypothetical fact situation presented is as follows: 1.     The taxpayers have been resident in Israel for 10 years; 2.     They own shares in a private Canadian holding corporation ("Holdco"); 3.      ...

Osborn   (613) 957-2120 19(1) June 29, 1990 Dear Sirs: Re:  Subsection 55(2) of the Income Tax Act (the "Act") We are writing in response to your letter of February 19, 1990. You requested our comments regarding the application of subsection 55(2) of the Act in the following hypothetical circumstances. (1)     Opco is a Canadian-controlled private corporation and  a taxable Canadian corporation within the meanings of paragraphs 125(7)(b) and 89(1)(i) of the Act, respectively. (2)     The common shareholders of Opco are married individuals owning 65 per cent and 35 per cent of the issued shares respectively. (3)     The corporation has a fair market value of $1,000,000 represented by $800,000 of active business assets and $200,000 cash. (4)     The corporation has accumulated $500,000 in safe income for the purposes of subsection 55(2) of the Act. (5)     The shareholders intend to sell 50 per cent of each of their shareholdings to an arm's length party for $500,000. (6)     Before the intended sale, a new company ("Newco") is incorporated, and the spouses transfer one half of their respective shares of Opco to Newco pursuant to the provisions of subsection 85(1) of the Act and receive common shares of Newco as consideration.  The agreed amount under paragraph 85(1)(a) of the Act will equal the adjusted cost base, as defined under paragraph 54(a) of the Act, of the Opco shares. (7)     The common shares of Opco owned by Newco are then exchanged, under the provisions of section 86 of the Act, for Voting, redeemable, retractable preference shares having an aggregate paid-up capital equal to the paid-up capital of the common shares exchanged. (8)     The preference shares will be redeemable at an amount of $500,000 less any dividends paid on them before redemption. (9)     Opco then declares a $200,000 dividend on the preferred shares. ...

25 September 1989 Ministerial Letter 58508 F- Deferred Salary Leave Plan for Teachers Unedited CRA Tags 6801(a) 19(1) File No. 5-8508   A.B. Adler   (613) 957-8962 September 25, 1989 Dear Sirs: This is in reply to your letter of August 4, 1989 in which you requested a technical interpretation concerning a proposed deferred salary leave plan ("Plan") for teachers. ... Our comments with respect to your Plan are as follows. 1.     Clause 3.2 of the Plan should make it clear that the maximum percentage deferral in any taxation year of a participant cannot exceed 33-1/3% of the amount of salary or wages that the participant would normally receive in that year (subparagraph 6801(a)(ii) of the Regulations). 2.      ...

Opco is a Canadian-controlled private corporation within the meaning assigned by paragraph 125(6)(b) of the Act. 2.      ... Included in such assets is real estate with a fair market value of $2,000,000. 4.      ... A, B and C would respectively receive 62.75%, 25% and 12.5% of the Opco Preferred Shares and the new common shares. 6.      ...