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If we can be of any further assistance in resolving tax problems in connection with this undertaking please feel free to contact us. ...

Our Comments Subsection 28(1.1) defines, for purposes of subsection 28(1), inventory owned in connection with a farming business, as "property that would have been included as inventory of the business if the income from the business had not been computed in accordance with the cash method, and includes livestock but does not include animals included in a taxpayer's basic herd (within the meaning assigned by section 29). ...

A ruling request must also contain a statement as to whether any of the issues involved are to the best of the taxpayer's knowledge being considered by a District Office and/or Taxation Centre in connection with a tax return already filed, or if any of tee issues are under objection. ...

(b)       Whether the guarantee fees arising from or in connection with the loan obligation acquire the same characteristics as interest payments on the loan obligation. ...

If we can be of any further assistance in resolving tax problems in connection with this undertaking please feel free to contact us. ...

It also states that a payment made after December 20, 1991 that is otherwise a periodic pension payment would not be a periodic payment and thus subject to the full 25% Part XIII tax where, subject to certain exceptions, the total of all payments made under the RRIF at or before that time of the payment and in the year exceeds the greater of (a) twice the amount that would be the minimum amount under the fund for the year, and (b) 10% of the amount that would be the fair market value of the property held in connection with the fund at the beginning of the year if all property transferred in the year and before that time to the carrier of a fund as consideration under the fund had been transferred immediately before the beginning of the year and the definition of "minimum amount" in paragraph 146.3(1)(b.1) of the Income Tax Act were applicable with respect to all RRIF's. ...

Pembroke 920651 Overseas Employment Tax Credit This is in reply to your memorandum of March 2, 1992 wherein you requested our opinion whether or not an individual in the following situation qualified to claim an Overseas Employment Tax Credit (OETC). 24(1) 24(1) An individual may claim an OETC where he is resident in Canada in a taxation year and, throughout any period of more than 6 consecutive months that commenced before the end of the and year and included any part of the year, he was employed by a person who was a specified employer (subject to an exception which is not applicable in this case) and performed all or substantially all the duties of the individual's employment outside Canada in connection with a contract under which the specified employer carried on business outside Canada with respect to a qualified activity. ...

In this connection, it is our understanding that the purpose of section 19 was dual: (a) to deter the take over of Canadian publications by non-residents, and (b) to prevent foreign publications from dominating the Canadian publication industry, by denying deductions for advertising in foreign publications by Canadian taxpayers. ...

In the case of principal shareholder-managers of a corporation, the Department generally will not consider their remuneration excessive in the following circumstances: the corporation's normal practice is to distribute its profits to these individuals in the form of bonuses or additional salary, or the corporation has a policy of declaring bonuses to the shareholder- managers for corporate profits stemming from special knowledge, skills ar connections, etc. of that person. ...

No shares will ever be issued in connection with the option agreement. ...