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Partnerships 7-920955- 66.1(6)(a)(iv) & (v) March 31, 1992 This request is for comments with respect to a strictly technical argument that a partnership's CEE earned under a flow-through share agreement pursuant to subparagraph 66.1(6)(a)(v) is CEE of the partnership solely by virtue of that subparagraph. ...

In previous years when the Canadian individual received a cash dividend, he was in a position to recover the tax withheld in excess of 15% of the gross amount of the dividend (i.e. 10 % of such amount) from the U.K. authorities in accordance with Articles X and XXVII (Miscellaneous Rules) of the Convention. ...

(note 3) 199 464,16 1 010,84$ Suite à ce roulement, vous indiquez qu'une réduction du capital versé permettrait de remettre à l'actionnaire 26 149,50$ (25 138,66 + 1 010,84$). ...

., commented that "... the word `payable'... is synonymous with due, a present obligation to pay... 24(1) 24(1) 14. ...

You asked us whether a T2060 is required for each former partner and whether the penalty is required to be paid by each former partner. 21(1)(a) 21(1)(b) Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ` ...

Farrell Chief of Verifications & Collections Revenue Canada, Taxation Mississauga District Taxation Office P.O. ...

Convention on the other hand, where payments in excess of the "minimum amount" are withdrawn in a year, such payments would not even fall under the definition of "pension" because the definition found in Article XVII(3) excludes: "... any payment under a retirement plan... in settlement of all future entitlements... ...

Chief Services, Public Utilities & Exempt Corporations Section Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

In addition, a review of Falconbridge on "Banking and Bills of Exchange" states on page 759 that "... a "deposit" could, depending on the contractual terms, refer to money loaned to a bank in exchange for any kind of document evidencing such indebtedness, including... bank passbooks". ...

(c) Since a partnership is by definition "... the relation that subsists between persons carrying on business in common with a view to profit" (paragraph 2 of IT-90) it is our view that the sale of assets to a corporation by the LP followed shortly thereafter by a sale of the capital shares by the LP could also be an adventure in the nature of trade. ...