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19 December 1990 Ruling 903423 F- Expropriation Proceeds Unedited CRA Tags 13, 44, 96(1)(a) 24(1) 903423   L. Holloway   (613) 957-2104 Attention:  19(1) December 19, 1990 Dear Sirs: Re:  Taxation of Expropriation Proceeds, your file 24(1) This is in reply to your letter of December 5, 1990 requesting a technical interpretation on the application of the replacement property rules in sections 13 and 44 of the Income Tax Act ("the Act") to the situation described below. Facts The facts you have presented are is follows: 24(1) 5.     24(1) Your Opinion 24(1) Our Comments Since the situation described above involves actual taxpayers and completed transactions, we are unable to comment specifically on the issues set out in your letter. ...

The outstanding shares are owned as follows: XXXXXXXXXX % by XXXXXXXXXX who is a Principal ("Principal A") and XXXXXXXXXX % by XXXXXXXXXX. ... The outstanding shares are owned as follows: XXXXXXXXXX % by XXXXXXXXXX who is a Principal ("Principal B") and XXXXXXXXXX % by XXXXXXXXXX. ... The outstanding shares are held as follows: XXXXXXXXXX % by XXXXXXXXXX who is a Principal ("Principal F") and XXXXXXXXXX % by XXXXXXXXXX. ...

Ainsi, l'offre d'achat tient compte d'un achalandage total de XXXXXXXXXX $ dont un montant de XXXXXXXXXX $ est attribué à l'achalandage XXXXXXXXXX des magasins corporatifs exploités par XXXXXXXXXX. Le chiffre de XXXXXXXXXX $ sera majoré de XXXXXXXXXX $ si les Acheteurs, XXXXXXXXXX, prennent possession d'un bail pour XXXXXXXXXX lui permettant d'y opérer XXXXXXXXXX, après expiration de la durée du bail actuel. ... Ce montant représentera le prix de rachat des actions, au montant de XXXXXXXXXX $, moins l'impôt de la Partie XIII devant être retenu sur la partie du prix de rachat représentant le montant du dividende imposable soit XXXXXXXXXX $. ...

19 October 1989 Ruling 74171 F- Form T2205 Unedited CRA Tags 146(8.8), 146.3(6), 146(8.7)(e), 146.3(5.5)(d)   October 19, 1989 P. ... Parnanzone   957-9232 Attn:  Rick Owen   File:  7-4171 Subject:  Form T2205 Rev. 89 This is in reply to your request (T782) of July 24, 1989 to review the above-noted form. ...

27 November 1989 Ruling 941221 F- Disposition of Taxable Canadian Property Unedited CRA Tags n/a   November 27, 1989 Mr. ... Watson   957-2072 Attention:  George Lalonde   HBW 9412-21 Disposition of Taxable Canadian Property By a Foreign Government We have enclosed a copy of a letter dated November 16, 1989, and attachments thereto, concerning the disposition of a taxable Canadian property owned by the 24(1) and administered by the 24(1).  ...

17 November 1989 Ruling AC204421 F- Request for Information on High Volume Mail Unedited CRA Tags n/a   November 17, 1989 Tax Forms Directorate Provincial and International 875 Heron Road Relations Division Room 2150 A. Watson   957-2072 Attention:  L.A. Donnelly   HBW 2044-2-1 Request for Information on High Volume Mail Handling We have attached a copy of a letter dated October 26, 1989, from the 24(1) in which they outline plans for a new building with automated mail handling capabilities.  ...

You provided us with the following scenario: 1.     All of the parties are Canadian corporations. 2.     Corporation A agrees to contribute certain Canadian resource properties together with related tangible equipment to Corporation B. 3.     The price is determined by negotiation between these arm's length parties and settled on an amount of $100. 4.      ...

The issues involved herein are the subjects of Ruling # E 2004-009549 issued in respect of the above-named taxpayers. ... XXXXXXXXXX has passed a number of by-laws pursuant to section 81 of the Indian Act, including by-laws for the following purposes: * the regulation of traffic; * the observance of law and order; * the protection against and prevention of trespass by cattle and other domestic animals, the establishment of pounds and the appointment of pound-keepers; * to provide for disposal of garbage and waste; * to provide for the control of business establishments on the Reserve; and * to provide veterinary services to domestic animals. 3. XXXXXXXXXX provides and administers an extensive list of public works, social services and infrastructure programs for the Members, including but not limited to: * education programs; * health programs; * housing programs; * garbage disposal services; * water and sewage services; * fire protection services; * maintenance of infrastructure programs, including roads, sanitation and landfill; * recreation and social programs; * social services; and * financial management and economic development. 4. ...

Position: 1 & 2 – No. 3 – Yes, provided the production does not subsequently become an excluded production (i.e. the 25-year copyright ownership requirement continues to be met) and the production meets the other requirements of a Canadian film or video production under subsection 1106(4) of the Regulations. Reasons: 1 & 2 – Clause 1106(1)(a)(iii)(A) of the definition of "excluded production" in the Regulations contemplates a transfer of the copyright between a qualified corporation and a related prescribed taxable Canadian corporation. 3 – Wording of provisions (including subsection 1101(5k.1) of the Regulations which contemplates a transfer of the production between a qualified corporation and a related corporation). ...

The Class XXXXXXXXXX Special Shares will be issued as provided in paragraph 70 of the Ruling to the following Class XXXXXXXXXX Purchasers: Class XXXXXXXXXX Purchasers Purchaser Number of Class XXXXXX Special Shares Purchaser's Aggregate Class XXXXXX Special Share Subscription Price XXXXXXXXXX XXXXXXXXXX $ XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX $ XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX $ XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX $ XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX $ XXXXXXXXXX XXXXXXXXXX $ XXXXXXXXXX Part B- The Additional $XXXXXX of Class XXXXXX Special Shares Background As mentioned above, you advise that the issue of $XXXXXXXXXX of Class XXXXXXXXXX Special Shares by XXXXXXXXXX and $XXXXXXXXXX of Class XXXXXXXXXX Special Shares by XXXXXXXXXX were completed in accordance with the Ruling on XXXXXXXXXX, 1997 (the "Closing"). ...