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In view of your comments concerning the desire of mutual fund investors to obtain more information on tax issues raised by mutual fund managers, we will give serious consideration to the publication of additional ATRs that will address some of these issues. ...

We have forwarded all information from the Institute to our International Tax Programs Directorate for possible future consideration. ...

The Income Tax Act contains numerous provisions pertaining to the organization and operation of not-for-profit and charitable organizations and, as a result, like commercial enterprises, advance rulings may also be required to provide assurance with respect to the income tax implications of transactions under consideration. ...

We will, however, bring this matter to the attention of the Department of Finance for their consideration. ...

Paragraph 23 of the Ruling is replaced with the following: Subsequent to the Capital Reorganization, the following transactions will occur in sequence on XXXXXXXXXX as part of the Lossco Proposal: (i) Parentco, the parent corporation of Opco, will subscribe for 1 Lossco Preferred Share; (ii) Lossco will redeem the Lossco Preferred Share held by the trustee-in-bankruptcy for aggregate consideration of $XXXXXXXXXX, which will result in Parentco becoming the sole shareholder of Lossco; (iii) Parentco will subscribe for 1 common share of Lossco for $XXXXXXXXXX; and (iv) Lossco will redeem the remaining Lossco Preferred Share held by Parentco with the result that Parentco will own only the single common share referred to in (iii) above, which will have a paid-up capital of $XXXXXXXXXX. 3. ...

Proposed subsection 248(31) provides that the amount of the advantage is generally the value of any property, service, compensation or other benefit received or obtained by the donor as partial consideration for, or in gratitude for, the gift. ...

If, however, this situation relates to a factual situation and a completed transaction, it should be submitted to the appropriate taxation services office for their consideration. ...

Your Question You have indicated that the Canada Customs and Revenue Agency (the "CCRA") has taken the view (paragraphs 38(b) and 39 of Interpretation Bulletin IT-474R) that where a taxpayer receives cash in lieu of fractional shares as a result of an amalgamation under subsection 87(1), the taxpayer will not be disqualified from the rollover treatment provided under subsection 87(4) and where the amount of cash received is less than $200, the taxpayer may either reduce the adjusted cost base, as defined in section 54, of the share consideration received or compute a gain or loss in respect of the appropriate fraction. ...

We recognize that the restrictions in paragraph 118.2(2)(n) may have been drafted without consideration of the unique circumstances faced by the taxpayer. ...

Where the shareholder or employee, as the case may be, and the corporation are dealing at arm's length and the shareholder or employee pays FMV consideration to the corporation to acquire the policy, it is our view that such a transfer would not be considered to have been made by way of gift, by operation of law only or by distribution from the corporation. ...