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14 February 1980 Income Tax Severed Letter RCT 5-1327 F

The facts as we understand them are as follow: You ask us to review the matter and to advise you if this is a case of dividend stripping, based upon strictly technical considerations as there was no attempt to disguise the facts, except perhaps by overvaluing the adjusted cost base. ...

7 April 1982 Income Tax Severed Letter RCT 5-3867 F

Common shares of HOLDCO are received as the only consideration. 3. The common shares of OPCO are converted on a tax-free basis under section 86 of the Act into preferred shares of OPCO having a fair market value and paid-up capital equal to the fair market value and paid-up capital of OPCO's common shares. 4. ...

21 June 1988 Income Tax Severed Letter RCT 5-5958

As a result, the mutual fund corporation shares received by the partnership in exchange for the cash would not be received from the mutual fund corporation as consideration in respect of any disposition to which subsection 85(2) of the Act applied. ...

25 January 1989 Income Tax Severed Letter 5-7199 - Income tax consequences of financial arrangements designed to facilitate family farm purchase and sale transaction

The comments set out in this letter are of a general nature and do not take into account the numerous additional considerations that might arise in the context of specific factual situations. ...

25 May 1990 Income Tax Severed Letter 9208003 - Remission of tax, penalty or interest liability

However, after careful consideration of the matters outlined in his letter, I regret that I am unable to recommend the remission of his tax, penalty or interest liability. xxxxx has been treated in a fair and reasonable manner similar to any taxpayer in like circumstance. ...

15 April 1992 Income Tax Severed Letter 9208505 - Clergyman's residence — housing allowance remuneration

As a consequence we believe that favourable consideration should be given to XXX request in this respect. ...

19 June 1989 Income Tax Severed Letter 5-7990 - Deductibility of payments made under a participating loans

As was the case with the comments made during the 1988 Round Table, the comments made in this letter are purely of a general nature and do not take into account considerations that might arise in the context of a specific transaction or event. ...

10 January 1992 Income Tax Severed Letter 9122137 - Transaction to protect asset from operational risk

The transfer is made in consideration of preferred rollover shares which are subsequently redeemed, giving rise to a deemed dividend. ...

23 April 1992 Income Tax Severed Letter 9212115 - Dividend reinvestment plans

Chisolm 921211 Dividend Reinvestment Plans (DRIPS) Further to our meeting of April 15, 1992, (Francis/Chisolm), we are forwarding the correspondance concerning DRIPs for your consideration. ...

11 July 1988 Income Tax Severed Letter 7-2569 - Commodities Futures Exchange

Interest is the return or consideration or compensation for the use or retention by one person of a sum of money belonging to another (Reference re Validity of Section 6 of the Farm Security Act, 1944, of the Province of Saskatchewan [1947] S.C.R. 394 at pp. 411-412); 2. ...

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