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13 November 2020 Internal T.I. 2020-0864831I7- Equity award plan and recharge agreement Unedited CRA Tags 7(3)(b), 248(1) “salary deferral arrangement”, 20(1)(oo), 15(1), 212(2)(a), 214(3)(a), 246(1) * Principal Issues: 1. ...

XXXXXXXXXX 2021-087667 XXXXXXXXXX, 2021 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – Transfer between U.S. pension plans XXXXXXXXXX This is in reply to XXXXXXXXXX email of XXXXXXXXXX requesting that we resume our consideration of the request for an advance income tax ruling (“Ruling”) on behalf of the XXXXXXXXXX that was originally submitted in XXXXXXXXXX letter of XXXXXXXXXX. ...

The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

The maximum CCA which Corporation AC may claim in respect of its 1988 taxation year is computed per paragraph 1100(l)(ta) of the Regulations as follows: An amount not exceeding the aggregate of: i) the aggregate of A) the lesser of Subtotals Totals i) 50% of the capital cost of designated property acquired in the year (50% of XXX) ii) UCC in respect of designated property acquired by virtue of specified transaction B) 25% of the lesser of I) UCC not including designated property acquired during the year II) capital cost of non-designated property acquired during the year Subtotals ii) the lesser of A) excess of UCC over capital cost of all property acquired in the year NIL B) an amount equal to the aggregate of I) 50% of capital cost of property acquired in preceding years NIL II) excess from clause A over amounts related to prior years NIL NIL NIL Available CCA as at June 30, 1988 for Corporation AC $86,562.50 ========== These comments represent our opinion of the law as it applies generally. ...

" Le terme "taxes'" est définie aux fins de l'application du paragraphe 23(2) de la Loi sur la gestion des finances publiques au paragraphe 23(1) de cette même loi 23. (1) Les définitions qui suivent s'appliquent au présent article. (...) ...

At the lower court level it was found that to constitute an amount receivable "... it was not enough to have a precarious right to receive the amount in question, but he must have a clear legal, though not necessarily immediate, right to receive it". ...

We suggest the following wording: The legal text analyzed in this Tax Analysis was published in the 1987 edition of the Income Tax Act, which consolidates amendments made up to December 19, 1986. p. 6- in “commentaries”- A statement is made that “... no other consideration BUT SHARES may be received by either party.” ...

., by deleting "three-quarters of " and by replacing "you are required" with "you may be required"). ...

Our Comments The fact that the special shares were issued for nominal consideration and have an aggregate redemption value of $ 199,665 does not mean that subsection 110.6(9) does not apply. ...

Position: Reduced accommodation charges- no, XXXXXXXXXX Payments- yes, PUA payments – yes. ...