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This is in reply to your letter of February 26, 2002, in which you ask whether subsection 75(2) of the Income Tax Act, R.S.C. 1985 (5th supp.) c. 1, as amended (the "Act") would apply to attribute royalty income from an oil and gas property to the settlor of a discretionary trust. ... In Income Tax Technical News No. 10, dated July 11, 1997, it is stated that: Revenue Canada has traditionally taken the view that a net profits interest (NPI) would constitute a CRP where it entitled the holder to share in the net proceeds from the production and sale by the grantor of the NPI of oil or gas (footnote 1), or the output from a mineral resource in Canada. [...] the Department will accept that in situations similar to the above, an NPI can qualify as a CRP where the conditions of the NPI provide that 90% or more of the total payments for each particular year under the NPI will directly relate to the amount or value of the NPI grantor's production during that year from: i) an oil or gas well in Canada; ii) a natural accumulation of petroleum or natural gas in Canada; or iii) a mineral resource in Canada from which the NPI was granted and, in addition, the remaining payments will be connected to the operation of the above resource property from which the NPI was granted (the "90% test"). ...

In summary, if the first series qualified for distribution to the public, any of the following scenarios would enable the trust to qualify: 150 unitholders of 100 units of the first series; 150 unitholders of 25 units of the second series; (150- N) unitholders of 100 units of the first series + N unitholders of 100 units of the second series. ... Brooks 2002-016754 February 12, 2003 Dear XXXXXXXXXX: Re: Section 4801 of the Income Tax Regulations This is in reply to your letter dated October 9, 2002, in which you requested our views on section 4801 of the Income Tax Regulations as it would apply in a hypothetical situation in which the units of a unit trust consist of one class issued in two series, one of the series having a fair market value of less than $25 per unit and the other having a fair market value of more than $25 but less than $100 per unit. ...

Position: Scenario 1, 2 & 3: Question of fact. Scenario 4: Question of fact but likely yes. Reasons: Scenario 1, 2 & 3: Overview of relevant Treaty Articles provided. ... Yours truly, Lita Krantz for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

2 March 2005 External T.I. 2004-0084891E5- Securities lending arrangement Unedited CRA Tags 260(1)(c) 260(5) & (6) 260(8) Principal Issues: (a) Does CRA interpret the words in paragraph 260(1)(c) of the definition of a "securities lending arrangement" ("Definition") as meaning that a borrower of a qualifying security must have disposed of the security before a dividend is paid by the issuer in order to meet the dividend compensation payment criteria in the said paragraph? ... (c) That CRA confirm your understanding of our technical interpretation letter (our file # 2001-0087365) which sets out our views on lending arrangements under a short sale agreement to which section 260 of the Act does not apply ("non-qualifying lending arrangements"). ... Written confirmation of the tax implications inherent in particular transactions are given by this Directorate only where the transactions are proposed and are the subject matter of an advance ruling request submitted in the manner set out in Information Circular IC-70-6R5 dated May 17, 2002. ...

General Comments As stated in paragraph 2 of Information Circular 70-6R5, "Advanced Income Tax Rulings", dated May 17, 2002, an advance income tax ruling is a written statement given by the Directorate to a taxpayer stating how the CRA will interpret and apply specific provisions of existing Canadian income tax law to a definite transaction or transactions which the taxpayer is contemplating. ... Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

For more information about how to obtain a ruling, please refer to Information Circular 70-6R5, "Advance Income Tax Ruling", dated May 17, 2002. ... Yours truly, Daryl Boychuk Manager, International Section I International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ... In that case, Judge Estey, J. concluded that "... one is ordinarily resident in the place where, in the settled routine of his life he regularly, normally or customarily lives". ...

The Definition reads as follows: " "eligible apprentice" means an individual who is employed in Canada in a trade prescribed in respect of a province or in respect of Canada, during the first twenty-four months of the individual's apprenticeship contract registered with he province or Canada, as the case maybe, under an apprenticeship program designed to certify or license individuals in the trade;" Quebec- the CCQ In Quebec, apprentices in the construction trades are required to be registered as apprentices with the CCQ. ... Our Comments Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ...

La prime annuelle est de 10 000$ et le capital assuré est de 500 000 $. ... Nos commentaires Tel qu'il est mentionné au paragraphe 22 de la Circulaire d'information 70-6R5 du 17 mai 2002, l'Agence du revenu du Canada (ARC) a comme pratique de ne pas émettre d'opinion écrite concernant des transactions projetées autrement que par voie de décisions anticipées. ...

On January 1, 2002, Y Co borrowed US $1000 (the "Debt") from X Co to finance the purchase of a business. ... OUR COMMENTS Interaction of subsection 80.01(3), subsection 80(1) "Forgiven amount" and paragraph 80(2)(k) Subsection 80(1) defines the term "forgiven amount", in part, as follows: " 'forgiven amount' at any time in respect of a commercial obligation issued by a debtor is the amount determined by the formula A- B Where A is the lesser of the amount for which the obligation was issued and the principal amount of the obligation, B is the total of, a) The amount, if any, paid at that time in satisfaction of the principal amount of the obligation,.... ...