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8 December 1989 Ministerial Letter 59178 F- Trust Funds for Prepaid Funeral Services Unedited CRA Tags n/a 19(1) 5-9178   Maureen Shea-DesRosierss   (613) 957-8953 December 8, 1989 Dear Sirs: Re:  Trust Funds for Prepaid funeral Services This is in reply to your letter of November 30, 1989, concerning the above-mentioned subject. ...

1 June 1989 Ministerial Letter 58118 F- Joint Exploration Company Unedited CRA Tags 66(15) joint exploration corporation 19(1) File No. 5-8118   G.R. White   (613) 957-8585 June 1st, 1989 Dear Sirs: Re:  Joint Exploration Corporation As requested in your letter of May 11, 1989, we confirm that a principal business corporation will not be disqualified as being a "joint exploration corporation", within the meaning of paragraph 66(15)(g) of the Act solely by virtue of its having had, in the aggregate, more than ten (10) shareholders at any particular time. ...

30 June 1989 Ministerial Letter 58248 F- General Anti-Avoidance Rule Unedited CRA Tags 245(2) 19(1) File No. 5-8248   S.J. Tevlin   (613) 957-2118 Dear Sirs: Re:  Subsection 245(2) of the Income Tax Act (the "Act") This is in response to your letter of June 15, 1989, concerning subsection 245(2) of the Act.  ...

For instance, it has already been determined that the exemption will apply to:-     employment income for duties performed entirely on a reserve;-     employment income for duties performed entirely off a reserve where the employer resides on a reserve and the Indian lives on the reserve;-     employment income for duties, a substantial amount of which are performed on a reserve and either the employer is located on the reserve, or the Indian lives on the reserve; and-     unemployment, pension and retiring benefits received in respect of exempt employment income. ...

For instance, it has already been determined that the exemption will apply to:-     employment income for duties performed entirely on a reserve;-     employment income for duties performed entirely off a reserve where the employer resides on a reserve and the Indian lives on the reserve;-     employment income for duties, a substantial amount of which are performed on a reserve and either the employer is located on the reserve, or the Indian lives on the reserve; and-     unemployment, pension and retiring benefits received in respect of exempt employment income. ...

Some of the more important conditions that an association or organization must comply with to qualify for exemption are as follows: (a)     it must not, in the opinion of the Minister, be a charity; (b)     it must be organized exclusively for social welfare, civic improvement, pleasure, recreation or any other purpose except profit; (c)     it must in fact be operated exclusively for one of the purposes mentioned in (b); and (d)     no part of its income may be paid, payable or otherwise made available for the personal benefit of any proprietor, member or shareholder, except in connection with the promotion of amateur athletics in Canada. ...

It reads as follows: "employment income for duties performed entirely off a reserve      where the employer resides on a reserve and the Indian lives on the reserve;" It is your understanding, from comments made in XXXXXXXXXX that the exemption would cease to apply to your employees since the work was performed off-reserve and the employer was neither an Indian nor an Indian Band. ... Yours sincerely, Denis LefebvreAssistant Deputy Minister Legislative and Intergovernmental Affairs Branch c.c.       ...

19 October 1990 Ministerial Letter 902468 F- Change of Control Unedited CRA Tags 249(4), 256(7) 24(1) 902468   M.P. Sarazin   (613) 957-2125 19(1) October 19, 1990 Dear Sirs: Re:  Subsections 249(4) and 256(7) of the Income Tax Act (Canada) (the "Act") This is in reply to your letter dated September 7, 1990 in which you requested an opinion regarding the application of subsections 249(4) and 256(7) of the Act to the following situation. 1.      ... There are no agreements or other factors which would give control of the company to either shareholder. 2.      ...

3 April 1990 Ministerial Letter 59778 F- Transfer of RRSP Funds on Death of Annuitant Unedited CRA Tags 146(8.1), 60(1), 146(8.9), 146(8.8), 152(4) 19(1) File No. 5-9778   D.S. Delorey   (613) 957-3495 April 3, 1990 Dear Sirs: This is in reply to your letter of March 12, 1990 concerning the transfer of registered retirement savings plan ("RRSP") funds on the death of the annuitant. ... Of particular relevance to your situation are the following comments contained in paragraph 19:      "Where a refund out of a depositary plan is paid after the death of the annuitant, Interest or income eventually paid that accrued after the date of death will be included in the income of the person entitled to the deposit (i.e., the estate of the deceased annuitant or the beneficiaries) and will not qualify as a refund of premiums. ...

13 March 1990 Ministerial Letter 58898 F- Related Corporations Unedited CRA Tags 251(3), 251(2), 251(1) 19(1) File No. 5-8898   Firoz Ahmed   (613) 957-2092 March 13, 1990 Dear Sirs: Re:  Subsection 251(3) of the Income Tax Act (Canada) (the "Act") This is in response to your letter of October 12, 1989 in which you requested our views as to the interpretation of subsection 251(3) of the Act in the context of the situation described below. Subsection 251(3) provides:      Where two corporations are related to the same corporation  within the meaning of subsection (2), they shall, for the purposes of subsections (1) and (2), be deemed to be related to each other. ...