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In particular, you inquired concerning the following situations: 1.      ... Interest free loan made by a Canadian partnership to a related non-resident. 3.     Interest free loan made by a trust resident in Canada to a related non-resident. 4.      ...

Facts 1.     During Period A, Mr. X, a non-resident, owned a Canadian rental property from which he earned gross rental revenues and in respect of the rental of which he incurred operating costs. 2.      ... X's rental activity did not constitute the carrying on of a business in Canada. 3.      ... X was less than his operating expenses in such year. 4.     Mr. X did not elect under subsection 216(1) of the Act to pay tax under Part I of the Act for any taxation year during Period A. 5.      ...

Facts The hypothetical facts, as we understand them, are as follows: 1.      ... B owns 100% of all shares issued and outstanding of A. 3.     A's assets consist of cash and non-depreciable capital property. 4.      ... A will be wound up into B under subsection 88(1) of the Act. 7.     The assets of A will be transferred to B upon the commencement of the wind up. 8.      ...

5 June 1990 Ministerial Letter 74678 F- Sale of Business- Amount Paid-Future Obligation Unedited CRA Tags 20(24), 12(1)(a)   June 5, 1990 TORONTO DISTRICT OFFICE Head Office   M. ... Cappella 957-2139   File No. 7-4678 SUBJECT: Sale of Business-Amount Paid-Future Obligations We are replying to your memorandum of January 26, 1990 concerning a situation where revenue is received in advance of the performance of services by a business and the business is subsequently sold. 24(1)  In relation to the above situation, you suggest that there is confusion concerning the effect of subsection 20(24).  ...

16 August 1989 Ministerial Letter 74118 F- Tax Shelter Registration Unedited CRA Tags 162(9) 19(1) File No. 7-4118   Bill Guglich   (613) 957-2102 August 16, 1989 Dear Sirs: Re:  Tax Shelter Registration This is in reply to your letter of July 10, 1989 concerning the application of subsection 162(9) of the Income Tax Act (the "Act"). You described the following situation: 1.     a person accepts fully refundable deposits in respect of interests in a tax shelter before September, 1989; and 2.      ... Yours truly, for Director Small Business and General DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch c.c.        ...

Kauffman   957-8953   File No. 7-4188 SUBJECT:  Version 10 of draft IT-359R3 In reply to a memorandum from Mr. ... Delorey of your Division dated July 27, 1989 we have the following comments on this version of IT-359R3: 1)     Paragraph 12- This paragraph generally reflects our approach.  ... Presently there is a "for example" within a "for example". 2)     Paragraph 11(b)- typo second word, second line. 3)     Comments from our memorandum of July 19, 1989 are otherwise correctly reflected. ...

28 September 1989 Ministerial Letter 74328- Bureau de district de minéral Unedited CRA Tags n/a   September 28, 1989 BUREAU DE DISTRICT DE MONTREAL Section des Services   bilingues M.F. ... Les informations requises sont les suivantes: 1.     Bilan d'ouverture de la succession 19(1) i.e. la liste, ainsi que la juste valeur marchande tous les actifs et de tous les passifs de 19(1)   la date de son décès; 2.     Un état détaillé (montants et dates) de tous les revenus de la succession réalisés au cours des années d'imposition sous étude; 3.      ...

For the purpose of this technical interpretation you have assumed the following facts: 1.          ... All of the director's meetings for Albertaco will take place at its head office situated on the Reserve. 5.      ... In carrying on business off the Reserve, the Partnership may use some of its equipment outside the Reserve. 7.      ...

B is a subcontractor who is not prepared to enter into a contract of employment with A Corp. 3.      ... The remaining common shares would be held by B. 4.     In addition to the common shares authorized by AB Corp, there would be two classes of special shares, Class A and Class B. 5.     Class A special shares would be issued to A Corp and Class B special shares would be issued to B. 6.      ...

12 January 1990 Ministerial Letter 59248 F- Qualified Investment- Registered Retirement Savings Plan Unedited CRA Tags 204 qualified investment, 204(e)(ix), ITR 4900(1)(b) 19(1) File No. 5-9248   D.S. Delorey   (613) 957-3495 January 12, 1990 Dear Sirs: Re:  Qualified Investment Registered Retirement Savings Plan ("RRSP") This is in reply to your query of December 14, 1989 requesting our views 24(1) Our Comments A share of a corporation will represent a qualifying investment for an RRSP where it is (a)     listed on a prescribed stock exchange in Canada (subparagraph 204(e)(iv) of the Act), (b)     listed on a prescribed stock exchange in a country other than Canada (subparagraph 204(e)(ix) of the Act), or (c)     a share of the capital stock of a public corporation, other than a share of a mortgage investment corporation that is not listed on a prescribed stock exchange in Canada (paragraph 4900(1)(b) of the Income Tax Regulations (the "Regulations")). 24(1) We trust the above comments will be of assistance to you. ...