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Although Revenue Canada does not have any predetermined rates per se, we offer our general comments for your consideration. ...

The issue of lease cancellation payments and their treatment for tax purposes is addressed in Interpretation Bulletin IT-359R2 and in particular paragraph 1 which states: "A premium or other amount received by a landlord or tenant, as the case may be, as consideration for granting or extending a lease or sublease, permitting a sublease, or cancelling a lease or sublease is business income to the recipient if renting property forms part or all of a business being carried on. ...

If your enquiry relates to proposed transactions, we would be pleased to give further consideration to these issues in the context of an advance income tax ruling request, where all relevant facts, documentation and other relevant information are available and those facts can reasonably be expected to prevail. ...

Nick Mulder, the Deputy Minister of Transport, for his consideration. ...

As the Department of Finance is responsible for tax policy relating to RRIFs, I have sent a copy of your letter to The Honourable Paul Martin, Minister of Finance for his consideration. ...

The XXXXXXXXXX shares will be issued for the price of $XXXXXXXXXX per share and the XXXXXXXXXX shares will be issued to the employees of XXXXXXXXXX for nominal consideration. ...

However, in our opinion, if such an acquisition of property (the "Acquisition") arose where the facts of the particular situation are such that: i)     the Acquisition would be in the ordinary course of the "particular corporation's" business and would have occurred whether or not the Butterfly Reorganization is subsequently undertaken; ii)     neither the structure or timing of the Acquisition would be affected by considerations relating to the Butterfly Reorganization; and iii)     the Acquisition would not be conditional on completion of the Butterfly Reorganization;      the Acquisition would not normally be considered to have occurred in contemplation of the Butterfly Reorganization. ...

Yuen XXXXXXXXXX (613) 957-8967 Attention: XXXXXXXXXX April 27, 1993 Dear Sirs: Re: Contributed Surplus We are writing in response to your letter of January 6, 1993 wherein you requested our views on the application of subparagraph 84(1)(c.3)(ii) of the Income Tax Act (Canada) (the "Act") in a situation where cash is contributed to a corporation by a shareholder for no consideration after March 31, 1977. ...

FA1 receives no non-share consideration from FAX on the transfer. 4)     As a final step, FA1 is liquidated in accordance with the provisions of subsection 88(3) of the Act. ...

3 May 1993 External T.I. 9307185 F- Contributed Surplus, Paid-up Capital Unedited CRA Tags 84(1)(c.3)   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Madam: RE:  Paragraph 84(1)(c.3) of the Income Tax Act (the "Act") This is in reply to your letter of March 3, 1993 wherein you requested our interpretation regarding the application of paragraph 84(1)(c.3) of the Act to the following situation: A Canadian resident individual has transferred shares (the "subject shares") of a corporation to another corporation (the "purchaser corporation") in consideration for shares of the purchaser corporation. ...