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It is also our view that the warrants issued by the corporation would not constitute "... a right to receive... shares" of the capital stock of the corporation for purposes of subsection 85(1) of the Act. ...

", whereas subsection 122.4(3) of the Act (FSTC) states that "... the amount... shall be deemed to be an amount paid... on account of... tax under this part... ...

It is also possible that simply setting aside assets (e.g. a second bank account) could constitute funding if the employee is identified with that asset (e.g. bank account #...- retirement fund for employee X), since such an action may create a trust (custodian) type of arrangement. ...

That definition, contained in proposed section 2, reads as follows: " "subordinated indebtedness" means an instrument evidencing an indebtedness of a company that by its terms provides that the indebtedness will, in the event of the insolvency or winding-up of the company, be subordinate in right of payment to all policy liabilities of the company and all other liabilities of the company except those other liabilities that, by their terms, rank equally with or are subordinate to such indebtedness;". ...

You propose to transfer the contract to Subco electing under section 85 of the Act at the amount of the deferred cost ($800.00 in your example) to achieve a “ rollover”. ...

" As the amounts paid by XXX Day & Ross Limited v. The Queen [[1976] C.T.c. 707] (76 DTC 6433 F.C. ...

While we cannot provide specific comments concerning the tax status of an existing corporation, we can provide comments concerning the interpretation of the requirement in paragraph 149(1)(j) of the Act that a corporation be "... constituted exclusively for the purpose of carrying on or promoting scientific research and experimental development... ...

7 December 1990 Income Tax Severed Letter- Scientific Research and Experimental Development Unedited CRA Tags Reg. 2900(2), (3), IT-151R3 QUESTION 1 SCIENTIFIC RESEARCH & EXPERIMENTAL DEVELOPMENT “SR&ED”) In paragraph 14 of Interpretation Bulletin IT-151R3, Revenue Canada states that current SR&ED excludes certain overhead, which would have been incurred regardless of whether SR&ED was carried on. ...

7 March 1991 Income Tax Severed Letter- Saskatchewan Capital Tax- Resource Surcharge Unedited CRA Tags 18(1)(m) Subject: Industry Issue Report # 5 Saskatchewan Capital Tax- Resource Surcharge ("Resource Surcharge") We are writing in reply to your memorandum of January 16, 1991, in which you requested our confirmation that the positions relied upon by you which are reflected in report #5 are current policies of Rulings in regards to the issue of whether paragraph 18(1)(m) is applicable to Resource Surcharges. ...

17 December 1992 Income Tax Severed Letter 9224127- Lease Options Unedited CRA Tags 20(1)(a) December 18, 1992 Edmonton District Office Financing & Leasing Section Attention: E.J. ...