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Senecal to 24(1) (copy attached). 24(1) 23 Section Chief Resource Industries Section Bilingual Services & Resource Industries Division Document Disclosed Pursuant to the Access to Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...

We note that the term "reserve" is defined in subsection 181(1) of the Act as "... the amount at the end of the year of all of the corporation's reserves, provisions and allowances... ...

The proceeds of the share issue are used by that corporation in its own operation to produce income from a business or property that will be subject to Part I tax in Canada, or are used by that corporation to loan to its Canadian subsidiary (IT-445 paragraphs 6 & 7) at less than a reasonable rate of interest (or at no interest), to be used in its operations to produce income from a business or property subject to Part I tax in Canada. 3. ...

Josee Vigeant, Ottawa District Office- Excise FILE # 5/920288 NOTES TO FILE GST transitional credits are included in income when received- see the 1991 fishermen tax guide p.8. ...

Ellis Enquiries & Office Examination Sydney District Office ...

The amount of a credit that is allocated to an employee is $ 24(1) The employer's contribution to the savings plan is immediately taxable to the employee. ...

In International Iron & Metal Company Limited v. MNR, [[1972] C.T.C. 242] (72 DTC 6205), a shareholder agreement was not considered relevant to the determination of control. ...

Former IT-436 contains comments in paragraphs 9 & 10 which, although not included in IT-436R due to the introduction of new 5 year time limit restrictions, are still considered relevant in some situations. ...

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. ...

Saint John Shipbuilding & Dry Dock Co. Ltd. [[1980] C.T.C. 352] (80 DTC 6272 at page 6274). ...