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DEPARTMENT'S POSITION Whether all, or any portion of, such fees or payments are subject to withholding tax is a question of fact which can only be determined with full knowledge of all of the facts concerning a particular situation and after consideration is given to the provisions under paragraph 212(1)(d) of the Act, Regulation 105 and the Canada-U.S. ...

In such case, fair market value consideration should be received by the Canadian corporation in respect of any property (e.g. eligible capital property) that is transferred to the subsidiary. 3) The comments in IT-454 entitled "Business Transactions Prior to Incorporation" may be of assistance in reference to the treatment of business transactions carried out prior to incorporation of the corporation that is intended to carry on the business. ...

XXXXXXXXXX Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...

Dunn Attention: XXXXXXXXXX June 10, 1996 Dear Sirs: Re: Taxable Preferred Shares We are writing in response to your correspondence of April 26, 1996 wherein you had requested that we give further consideration to our response of April 17, 1996 to you regarding the definition of "taxable preferred share" in subsection 248(1) of the Income Tax Act (the "Act") and, more specifically, whether that definition would apply to a share of a corporation the dividends upon which are attributable to the profits of a specific business division of a corporation. ...

As amendments to the Act relate to tax policy, which is the responsibility of my colleague, the Honourable Paul Martin, Minister of Finance, I have forwarded a copy of your letter to him for his consideration. ...

Grisé (613) 957-2059 Attention: XXXXXXXXXX December 23, 1996 Dear Sirs: Re: Medical Expenses This is in reply to your letter of October 22, 1996 requesting our further consideration in the matter of electrolysis and the medical expense tax credit. ...

A determination of the reasonableness of the amount of remuneration paid to any particular shareholder-employee requires consideration of the duties performed and the time spent in carrying out those duties. ...

We wish to point out however, that the requirements or non- requirements for an employer to withhold on contributions to an EPSP is presently under consideration. ...

When a bond is disposed of for consideration equal to its fair market value at the time of disposition, and where a taxpayer has accrued and reported interest income on that debt obligation, an amount may be deducted from the investor's income equal to the amount, if any, that the amount included in his income for the previous years exceeds the total interest actually received thereon. ...

You presented a hypothetical situation for our consideration of subsections 13(4), 44(1) and 44(5) of the Act. ...