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As requested, we are returning your materials with this memorandum. for Chief Leasing & Financing Section Rulings Directorate ...

In order to obtain the status that would permit it to receive deductible gifts, the U.S. organization must apply to Revenue Canada as described in paragraph 76(c) & (e) of Information Circular 77-16R3, a copy of which is attached. ...

(London: Stevens & Sons, 1982) c. 33, no 33-06 at 387 states in brief:... ...

The Queen Lease Inducement Payments Received by Tenant This is in reply to your memorandum of September 26, 1990, in which you requested our views on XXX In this memorandum: (a) “the first Consumers' Gas case” is a reference to, [[1982] C.T.C. 339] 82 DTC 6300 (FCTD), aff'd [] 84 DTC 6058 (FCA); and (b) “the second Consumers' Gas case” is a reference to, [[1986] 1 C.T.C. 380] 86 DTC 6132 (FCTD), aff'd. ...

In relating these comments to this definition, it states in part, "... a group life insurance policy under which no amount is payable to a person other than the group policy holder... before the death or disability of the taxpayer". ...

If Amalco was a member of the partnership before the particular time, can it be said that "... one, but not more than one, of the persons who were, immediately before the particular time, members of the partnership carries on by himself the business that was the business of the partnership. ...

Paragraph 21 of IC 70-6R2 [Information Circular 70-6R2] states that the Rulings Directorate will provide written opinions on the interpretation of specific provisions of the law, however, that paragraph goes on to say, "... when a requested interpretation relates to a contemplated transaction, a taxpayer should request an advance ruling rather than a opinion. ...

The appointment of a receiver does not divest the owner of his right of ownership in the assets (i.e. beneficial ownership) (In re Natural Gas Light & Appliance Co. (1918) 1 WWR 769); the appointment of a receiver has the effect of transferring possession of the debtor's assets to the receiver and permitting the receiver to deal with the assets. ...

The "cost amount" to the trust of the trust property so distributed will be determined as if the trust were a resident of Canada $7,500 (ii) Under paragraph 107 (2)(b), your client acquires the property at a cost, which is (A) the "cost amount" of the property to the trust $ 7,500 plus (B) the Adjusted cost base of your client's capital interest as at January 1, 1983 $6,600 less the "cost amount of his capital interest" (as defined in paragraph 108(1)(d)) $(7,500)_______ Excess of (A) over (B) NIL______ Cost of acquisition of property to your client $7,500______ (iii) Under paragraph 107 (2)(c), your client disposes of his capital interest for proceeds equal to (ii) above $7,500______ For the purpose of computing your client's taxable capital gain (if any) paragraph 107(1)(a) determines the Adjusted cost base of his interest to be the greater of the: Adjusted cost base of the interest (i.e. $6,600) and the "cost amount of his capital interest" (as calculated in paragraph 108(1)(d)) (i.e. $7,500). ...

Le paiement maximum des suppléments de transition est de 480 $. 6. Allocation de ré-intégration---------------------------- Un employé est éligible à cette allocation lorsque ses prestations de l'assurance-chômage sont terminées et qu'il a été incapable de se trouver un nouveau travail soit à cause de son âge, de sa santé, de son éducation ou toute autre raison valable. ...