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Current Amendments & Regulations Division Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...

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. ...

SUBJECT: RIGHTS & THINGS INTEREST INCOME SECTION: 70(1), 70(2)] 5- 921045 Franklyn S. ...

The particular provision is clause 212(1)(b)(iii)(D) of the Income Tax Act and the relevant wording is as follows: " any debt owing by a bank to which the Bank Act applies, as or on account of an amount deposited with that bank that is not repayable in canadian currency". ...

P Co has elected under subsection 216(1) of the Income Tax Act, Canada ("Act") to be taxed in respect of its Canadian source rental income on a "net " basis for its 1982 taxation year ended December 31, 1982; 6. ...

In our view, the application of subparagraph 69(1)(b)(i) of the Act does not affect the application of subsection 84(3), Subsection 84(3) applies to the actual proceeds by virtue of the words "... the amount paid by the corporation on the redemption... ...

We also doubt that the subsequent amount, if paid by the corporation, could be categorized as a dividend paid “... on the redemption...” of the particular shares as that phrase is contemplated in paragraph 84(3)(a) of the Act. ...

Francis (613) 957-3496 XXX Attention: XXX July 12, 1989 Dear Sirs: Re: XXX, Employee Savings & Share Purchase Plan (the "Plan") This is in reply to your letter of March 27, 1989, to our Registration Division wherein you requested our opinion in respect of proposed amendments to the Plan which will be effective on July 1, 1989. ...

Source Deductions Division Technical Research & Enquiries Section ...

The particular provision is clause 212(1)(b)(iii)(D) of the Income Tax Act and the relevant wording is as follows: " any debt owing by a bank to which the Bank Act applies, as or on account of an amount deposited with that bank that is not repayable in canadian currency". ...