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11 January 1988 Income Tax Severed Letter 7-1603 - Interpretation Bulletin Project Number 1386 Lease-Option Agreements, Sale-Leaseback Agreements Revision of IT-233R

As there is no provision in the Act dealing specifically with such agreements, this determination must be made after consideration of the terms of the agreement and surrounding circumstances, and the relevant provisions of the Act, in particular, the definitions of "disposition of property" in paragraphs 13(21)(c) and 54(c) of the Act. ...

2021 Ruling 2021-0894621R3 F - Paiement à un membre qui quitte

Dans sa décision de verser (ou non) cette Aide au Membre, la Communauté prendra indirectement en considération notamment: son âge, son éducation et ses probabilités d’obtenir (ou non) un emploi à la suite de son retour dans la société. ...

20 August 1992 Income Tax Severed Letter 9217167 - Progress Billings - Holdback - Income Inclusion

The Bulletin has been prepared by taking into consideration the principle jurisprudence in this area, that being; Wilson and Wilson Limited v. ...

12 June 1992 Income Tax Severed Letter 9216345 - Over-reimbursement of costs under unitization

The second reason also presumes that the taxpayer has some economic benefit which constitutes a Canadian resource property and which he is relinquishing to the other participants who are making the overpayment in consideration therefor. ...

16 February 1999 Income Tax Severed Letter 9832857 - Corporate provincial permanent establishment

While these are undoubtedly relevant considerations, it is important not to give them inordinate weight. ...

7 July 1995 Income Tax Severed Letter 9528213 - Sale of Shares—Treaty Exemption

To achieve this result, XXXXXXXXXX transferred its holdings of XXXXXXXXXX to XXXXXXXXXX for share consideration. ...

7 July 1991 Income Tax Severed Letter - Various issues related to the large corporations tax

You have also noted the situation in which a drawer discounts a banker's acceptance that is issued in its name for which it receives the present value of the acceptance in consideration for its promise to compensate the holder of the acceptance should the bank dishonour it. ...

7 December 1991 Income Tax Severed Letter - Tax treatment where a Canadian resident rolls an American 401(k) plan into an American individual retirement account

Paragraph 56(1)(a) of the Income Tax Act (the "Act") lists benefits under an EBP as being superannuation or pension benefits which are excluded from consideration under that provision. ...

7 December 1990 Income Tax Severed Letter - Section 85 transfer by non-tesident; Trusts—dividends paid to corporate beneficiary; Capital gains deduction—sale to spouse; GAAR—sale of shares; Income or capital gain: Rollover of assets followed by immediate sale of assets; Winding-up—cost amount of inventory; Rollover under section 85—benefit conferred on a related person; Deemed dividend on winding-up; Services between related Canadian corporations—paragraph 69(1)(b); Stock dividends; Indirect acquisition of control

Assuming that the compensation provided by the service agreement is sufficient for Company A to recover its cost of providing the services, would paragraph 69(1)(b) of the Act apply to deem Company A to have received fair market value consideration for providing the services? ...

7 August 1990 Income Tax Severed Letter - Application of subsection 55(2) of the Act to two situations

(c) New Xco will then redeem its preferred shares held by Brother Xco, the consideration being a demand promissory note having a value equal to the redemption amount. ...

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