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., 0.5 x (average net income /0.095 + (0.75 x net worth))- $125,000). ...

We trust that our comments will be of assistance to you. for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

. $ XXXXXXXXXX): XXXXXXXXXX. PROPOSED TRANSACTIONS The parties propose to enter into the following transactions on a date (the "Transaction Date") as early as practical after receiving the rulings given in this letter, provincial tax rulings, United States tax rulings and XXXXXXXXXX: 17. ...

Although the word "exclusively " is used in paragraph 149(1)(l) of the Act, the Agency has taken the position a corporation may carry on income generating activities and earn income and still qualify for exempt status provided that there is a causal relationship between the profit making activity and the exempt purpose of the corporation. ...

The Band Council only owned XXXXXXXXXX % of the shares. De facto control of the corporation was not with a person exempt from tax under section 149. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayer or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

Department of Fisheries & Oceans Allocation Transfer Program Questions and Answers For Canada Customs and Revenue Agency Client Services The Department of Fisheries and Oceans ("DFO") is responsible for issuing fishing licences which include commercial fishing licences to the public. ...

Avoid double tax 4. transactions arranged for other than tax purposes; no misuse / abuse XXXXXXXXXX 2000- 002842 Attention: XXXXXXXXXX XXXXXXXXXX, 2000 Dear Sirs: Re: XXXXXXXXXX Advance Income Tax Rulings We are writing in response to your letter of XXXXXXXXXX wherein you requested advance income tax rulings on behalf of the above taxpayer. ...

Where an employee of Employer exercises the Cash Out Right, and Employer pays the Cash Amount to the employee: (a) the Cash Amount received by the employee in respect of the economic value of the Subscription Right exchanged for the cancellation of that Subscription Right under the Subscription Rights Plan will be included in computing the income of the employee in the taxation year in which the Cash Amount is received by the employee in accordance with paragraph 7(1)(b) of the Act; and (b) assuming the conditions specified in subparagraphs 110(1)(d) are met with respect to the Foreign Parentco Shares and the Subscription Rights Plan, the employee may deduct 25 % of the Cash Amount in computing his or her taxable income for the taxation year in which the Cash Amount is received. ...

Also, see Doc # 32954. As there are good business reasons for undertaking the proposed transactions, the proposals are not avoidance transactions and GAAR should not be applied. ...