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22 May 1990 Income Tax Severed Letter RRRR289 - Review of Corporate Reorganizations Course Material — Lesson 5 Surplus Strips

However, if an election is made pursuant to subsection 85(1), the agreed amount cannot be less than the fair market value of the non-share consideration pursuant to paragraph 85(1)(b). ...

7 July 1991 Income Tax Severed Letter - Several issues pertaining to subparagraph 212(1)(b)(vii)

" Answer of Question 9 A definitive opinion in respect of a matter of this kind can only be formulated after a determination and consideration of all relevant facts. ...

7 September 1990 Income Tax Severed Letter - Deduction of large expenses that are incidental to the business

Kirk (1990) A.C. 588, a statutory provision under consideration provided for a tax on income arising from any trade carried on in New South Wales or derived from lands of the crown and stated that no tax shall be payable in respect of income earned outside the Colony. ...

7 August 1990 Income Tax Severed Letter - Amount of business limit

However, due to the fact that the words being interpreted by the court, i.e. the corporation, are different from those currently under consideration, the outcome of this case is not considered as a precedent in interpreting these words. ...

7 August 1990 Income Tax Severed Letter - Part I.3 tax on large corporations

Upon the wind-up, the acquiring corporation increases the book value of the assets of the acquired corporation by the difference between the consideration paid for the shares of the acquired corporation and book value of those assets. ...

7 September 1991 Income Tax Severed Letter - Determination of Residency

The temporary nature of the trip and ties within Canada have become the vital considerations. ...

7 September 1991 Income Tax Severed Letter - Qualified Small Business Corporation Share

In particular, we have insufficient information to enable us to determine how the capital gains will arise; however, in general, by virtue of paragraphs 86(1)(b) and (c) no capital gains will arise on a section 86 reorganization of capital where the only consideration received by the taxpayer is shares of another class of the capital stock of the corporation. ...

7 August 1991 Income Tax Severed Letter - Income Allocated to a Retiring Partner

The income calculated by a partnership pursuant to paragraph 96(1)(f) of the Act must take into consideration the partnership's election under paragraph 34(a) of the Act. ...

7 March 1991 Income Tax Severed Letter - Residual Interest in a Partnership

The $1 million in the capital account will be the net result of various additions to and reductions from that account, and these adjustments would have been taken into consideration for tax purposes by way of adjusting the ACB of A Co.'s partnership interest. ...

20 April 1990 Income Tax Severed Letter 5-9404 - [Subsection 256(1.4) of the Income Tax Act]

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

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