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For the purposes of the Act, subsection 251(2) provides that, persons related to each other are: individuals connected by blood relationship, adoption, marriage or common-law partnership; a corporation and a person that controls the corporation a person who is a member of a related group that controls the corporation, or any person related to a person described in either of the above two situations; and * any two corporations if they are controlled by the same person or group of persons, if each of the corporations is controlled by one person and the person who controls one of the corporations is related to the person who controls the other corporation, if one of the corporations is controlled by one person and that person is related to any member of a related group that controls the other corporation, if one of the corporations is controlled by one person and that person is related to each member of an unrelated group that controls the other corporation, (v) if any member of a related group that controls one of the corporations is related to each member of an unrelated group that controls the other corporation, or (vi) if each member of an unrelated group that controls one of the corporations is related to at least one member of an unrelated group that controls the other corporation. ...

Storry GAAR & Technical Support Section 957-3499 2000-005101 Strong Currency Loan Hedged by a Cross Currency Interest Rate Swap This is in reply to your memorandum of October 11, 2000, wherein you requested our views regarding payments made under a cross currency interest rate swap and whether such payments should be recharacterized as interest for purposes of Part XIII of the Income Tax Act (the "Act") when the desired currency was Canadian dollars and when the parties to the swaps and the underlying loans being hedged are all related. ...

July 13, 2001 Toronto Centre Tax Services Office HEADQUARTERS Verification & Enforcement Division Randy Hewlett, B.Comm. ...

October 3, 2001 Headquarters Headquarters SR & ED Directorate Income Tax Rulings Directorate Attn: Kevin Gibson F. ...

A sold XXXXXXXXXX % of his Opco shares to his adult son ("S") and XXXXXXXXXX% of his Opco shares to his daughter-in-law ("D"). ...

The postamble of the definition states, in part, "... and, for the purposes of this definition,... ...

& Yukon Tax Services Cornelis Rystenbil, CGA Aboriginal Affairs Section (613) 941-6547 2002-012281 RRSP Over-Contributions This letter is in response to your e-mail of February 7, 2002 in which you ask our views on several issues as they relate to Registered Retirement Savings Plan (RRSP) over-contributions made by members of the XXXXXXXXXX First Nation. a) Our Comments For purposes of this memorandum, the expression "Indian" has the meaning assigned by subsection 2(1) of the Indian Act. ...

" À notre avis, dans la situation que vous nous présentez, une partie du fonds de terre doit être attribuable à la location d'une partie du bâtiment puisqu'il serait peu probable qu'aucune partie du fonds de terre ne sert à la partie louée du duplex. ...

If so, then the terms were such that there would be an excluded production, as explained in our prior responses on this file (files 2000-005368 & 2001-006946). ...

We would also note that subsections 220(6) & (7) of the Act recognize that in certain instances a FTC refund may be assigned to another party. ...