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A proposal to increase the hourly fee from $65.00 to $80.00 and to increase the amount required to accompany the rulings request from $325.00 to $400.00 is currently under consideration. ...

Sheerin L'Esplanade Laurier 957-2079 16th Floor, East Tower I-3704 Ottawa, Ontario Dear Al: Re: Disability Riders attached to Group Term Life Insurance Policies Enclosed, for your consideration, is a copy of a recent memorandum (and attachment) from our Rulings Directorate concerning the interpretation of paragraph 6(1)(f) and subsection 6(4) of the Income Tax Act. ...

Specifically, you have requested our views as to whether a share issued to an employee of the issuer upon exercise of a stock option as contemplated in subsection 7(1) of the Act would qualify as a prescribed share under Income Tax Regulation 6204 if the employee/holder has the right, under the terms or conditions of the share or any agreement in respect of the share or its issue, to cause the share to be redeemed, acquired or cancelled by the issuer or "specified persons" in relation to the issuer, where the amount payable upon and in consideration for such redemption, acquisition or cancellation approximates the fair market value of the share at the time of such redemption, acquisition or cancellation. ...

As stated in question #13 of the 1980 Revenue Canada Round Table, the Department's concern is with the value of the shares received as consideration, either for shares transferred to the corporation, pursuant to subsection 85(1), or for the shares disposed of as part of a reorganization pursuant to subsection 86(1) of the Act. ...

As part of the consideration he receives a mortgage from the purchaser. 3. ...

Where grandchildren will share in the accumulating income of the trust once the child dies, it is our view that those grandchildren must be taken into consideration in determining the child's share under paragraph 2800(3)(f). ...

Of all the provinces, it appears that only Manitoba has taken this into consideration. ...

Our Comments Questions relating tax considerations of a particular taxpayer should be addressed to your local District Taxation Office. ...

You provided the following scenario for our consideration. Taxation Year Date of Deposit for Deduction to Spousal By Contributor RRSP Amount 1986 February 5, 1987 $1,000 1987 January 1, 1988 $1,000 1988 March 1, 1989 $ 500 The entire amount is withdrawn from the spousal RRSP on January 1, 1991. ...

It is the general position of the Department in this regard that if a borrower must first take some voluntary action before he is obliged to make a repayment of principal, that repayment should not be taken into consideration in determining whether or not the aforesaid "25% within 5 years" requirement is met. ...