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30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS-- summary under Subsection 146(10) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(10) Where cash is deposited as margin with a broker then, notwithstanding that such deposit would not be a qualified investment under s. 204(e)(i), s. 146(10) will not be applied to the annuitant if the transaction is concluded within a few days. ...

Dad invests $ in "trust" a/c for KIDS-- summary under Subsection 74.1(2) Summary Under Tax Topics- Income Tax Act- Section 74.1- Subsection 74.1(2) The word "transfer" means to "divest, deprive or dispossess of title". ...

17 December 1996 Internal T.I. 9625727- REMARRIAGE CLAUSE & DEF'N OF SPOUSAL TRUST-- summary under Subsection 70(6) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6) Where a will provided that the widow was entitled to receive the income of the estate but that her entitlement was "to be terminated upon her death or remarriage", and it is proposed that a court order be obtained removing the remarriage clause, RC will accept that the property of the estate vested indefeasibly in the spouse's trust within the 36-month period only if the court order is made within 36 months of the date of death. ...

31 March 1995 External T.I. 9430115- interest in a family farm partnership & capital gains RESERVE-- summary under Subparagraph 40(1)(a)(iii) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(1)- Paragraph 40(1)(a)- Subparagraph 40(1)(a)(iii) A reserve may not be claimed where an individual transfers property to a partnership pursuant to s. 97(1) and receives as consideration a promissory note payable over five years. ...

20 December 1995 External T.I. 9526825- ENTRY FEE PAYMENTS & WITHHOLDING TAX-- summary under Paragraph 212(1)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d) Discussion of factors bearing on whether surface lease payments are on account of capital (e.g., lump sum payments received as compensation for injurious affection of land that are treated as proceeds of disposition for purposes of s. 115(1)(b)(i)) or on account of income (subject to withholding tax under s. 212(1)(d)). ...

20 December 1995 External T.I. 9526825- ENTRY FEE PAYMENTS & WITHHOLDING TAX-- summary under Real Estate Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

& Section 116116(5)-- summary under Subsection 49(3) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(3) S.49(3) did not apply to deem the exercise of employee stock options held by a non-resident former employee to not be a disposition of the options, given that s. 49(3) applied only to capital property, whereas employee stock options are governed by s. 7. ...

18 December 2001 External T.I. 2001-0073925- Paragraph 88(1)(e.2) & Subsection 186(5)186(5)-- summary under Subsection 186(5) Summary Under Tax Topics- Income Tax Act- Section 186- Subsection 186(5) "While subsection 186(5) does not specifically refer to paragraph 88(1)(e.2) it is our view that such reference is not necessary. ...

2001 Ruling 2001-0077753- DIRECTORS FEES & STOCK OPTIONS-- summary under Paragraph 7(1)(a) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(a) options received on behalf of partnership Confirmation that where employees of the general manager of two partnerships sit on the board of directors of corporations on behalf of their employer, they are not required to report directors' fees and stock options paid to them as directors of the company. ...

1 May 2002 External T.I. 2002-0133145 F- RAP- BAIL & ACTIONS-- summary under Qualifying Home Summary Under Tax Topics- Income Tax Act- Section 146.01- Subsection 146.01(1)- Qualifying Home unit consisting of a leasehold interest and shares of the corporation owing the property could qualify as qualifying home Regarding the purchase of a unit that consisting of a leasehold interest in the property and a number of shares in the corporation that owns the property, CCRA noted that advance rulings had found that a unit consisting of a leasehold interest and shares, and giving its holder the right to the personal enjoyment of the housing unit would be a housing unit for the purposes of the definition of "principal residence", and that the acquisition of such a unit could qualify as a qualifying home for HBP purposes. ...