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It has been decided that we will not rule on freezes of this type for the following reasons; (i) The real intent of the proposed transactions is, generally, to sever the connection with Canada (without Canadian tax consequences) because there are greater overall tax benefits in a non-Canadian corporate structure. ...

You have asked us to clarify the Department's position in connection with the assignment of liability in relation to a structured settlement for damages arising from a personal injury or death claim by an individual. ...

Although such opinions are not binding, in order not to create situations of undue hardship, the Department's general practice is to carefully review the circumstances of each case in connection with any assess-ing action involving taxpayers that clearly relied upon the Department's opinions. ...

2 December 1982 Income Tax Severed Letter RCT 85-111 Unedited CRA Tags 85(1) This is in reply to your memorandum of November 16, 1982 in connection with the transfer by a fisherman of his "Nets and Traps" to a corporation using the provisions of subsection 85(1) of the Income Tax Act ("Act"). ...

It is not possible for us to state the appropriate tax treatment for all the different costs which may be incurred in connection with a winding up. ...

In connection with your comments about policy loan repayments, we note that the "policy loan" is not in fact a loan, but rather a withdrawal by the policy holder out of the cash value of his policy. ...

Furthermore, as you are aware, the views of the U.K. tax authorities (ie. in regard to the meaning of "activities" and "in connection with" as used in Article XXVIIA) were requested by Provincial and International Relations Division (at your request) and their reply basically confirmed the position we had taken. ...

The comments in this letter are of a general nature only and do not take into account considerations that might arise in connection with a specific transaction or event. ...

Further, you advised us that you are under some time constraints in this matter since your questions have arisen in connection with planning to be done for someone prior to a forthcoming remarriage. ...

In this connection, you ask if it makes any difference whether the exchanged shares were authorized shortly before and in anticipation of the exchange by the filing of articles of amendment or if they had been authorized before the exchange was contemplated. ...