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Calderwood Director RE: Continuity of Reserves I refer to your memorandum of December 16 in connection with GRIER v. ...

In this connection, the content of paragraph 4 of IT-239R2 is wholly applicable, wherein we say it is a question of fact if a bad debt exists to which subsection 50(1) applies. ...

The loan is obtained in connection with the borrower's United Kingdom permanent establishment and the interest is borne by the permanent establishment. ...

Earp (613) 995-1723 XXXX Dear Sirs: This will reply to your letter dated March 11, 1980 concerning the application of paragraphs 37.1(1)(b) and 37.1(5)(b) of the Income Tax Act as they relate to payments received from foreign governments or their agencies in connection with scientific research carried out by a Canadian resident corporation on behalf of the foreign governments and their agencies. ...

Negotiations with other countries in connection with prospective income tax agreements are the responsibility of the Department of Finance. ...

Rationale: The courts have indicated that where a vendor sells its business and in connection therewith assigns the rights under contracts to the purchaser, the purchaser's conside- ration for the contract rights which are acquired as part of the purchased business is treated as fixed capital and not as a deductible expense. ...

You describe a situation where a U.K. parent having a branch operation in Canada would establish a Canadian subsidiary which would purchase a building in Canada, with the only connection between the U.K. parent's Canadian branch and the new subsidiary being the possible management of the building, for which the branch would be paid a commercial fee. ...

Please let us know if there is any additional information you have in this connection. ...

Further, you may be aware that the ways and means motion 74 in the December 11, 1979 budget contained the provision that the references in section 206 of the Act to cost in connection with the holding after December 11, 1979 of foreign property be changed to references to the fair market value of such property. ...

In this connection, we draw your attention to paragraphs 3 and 12 of that Bulletin concerning property designated for a year after 1981 by a related person, such as your spouse or child, and land in excess of 1/2 hectare. ...