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However, after careful consideration of the circumstances, it is regretted that a recommendation cannot be made for the remission of taxes paid as a result of the 24(1) The law restricting the purchase of an IAAC became effective after November 12, 1981. ...

The notable example related to drilling rigs, although another case which is under consideration is one involving consultants and space being available in the offices of the hiring party in Canada. ...

After careful consideration of the matters raised, 24(1) When the remission guidelines are not met, the remission process cannot provide relief from taxation beyond that already made available by parliament to all taxpayers under the Income Tax Act. ...

A holding company is formed wholly owned by the individual and the operating company shares are transferred in for consideration of common shares and debt equal to the cost base. ...

This matter has been brought to the attention of Current Amendments for their consideration. ...

15 January 1993 Income Tax Severed Letter 9236060- Prepayment of Debt Unedited CRA Tags 18(9.1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. 1993 Manitoba Institute/Bar Revenue Canada Round Table- Question 13 Author: Steve Tevlin Date: January 15, 1993 Document Type: Code 7 T236 #: 923606 Section of Act: 18(9.1) Question (a) Where a financial institution lender receives payments from different borrowers, in each case as consideration for a reduction in the rate of interest payable on a debt obligation or as a penalty or bonus payable by reason of the repayment of all of or part of the principal amount of a debt obligation, will the lender in calculating its income for subsequent years consider such payments on an individual loan basis or an aggregate basis? ...

The purpose of paragraph 84.1(1)(a) of the Act is to prevent an individual taxpayer from receiving, in certain circumstances, consideration (other than debt or shares of the purchaser corporation) in respect of a corporation's pre-1972 surplus. ...

11 June 1992 Income Tax Severed Letter 2M01320- Term Preferred Shares Unedited CRA Tags 112(2.1) 1992 Corporate Management Tax Conference TERM PREFERRED SHARES Question 12 Will the Department, following the 1991 Tax Court of Canada decision in the Société d'Investissement Desjardins case [[1991] 1 C.T.C. 2214] (91 D.T.C. 393), take into consideration as one of the relevant factors in establishing whether particular term preferred shares were or were not acquired in the ordinary course of the business carried on by a corporation the fact that the corporation is a specified financial institution only by reason of being related to a financial institution and is not itself engaged in a financing business? ...

The concerns which you discussed with Jim Wilson of this office were taken into consideration while reviewing the 1989 General Tax Guide. ...

23 February 1986 Income Tax Severed Letter RCT 5-0266 F Unedited CRA Tags 40(1)(a)(iii) Dear XXX: RE:     Capital Dividend Account This is in reply to your letter of December 11, 1985 concerning whether or not a capital gain reserve that is to be brought into income at the end of the taxation year should be taken into consideration in the calculation of the Capital Dividend account that may be calculated at any particular time in the year. ...