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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. ...

7 September 1991 Income Tax Severed Letter - Deferral of lease payments

C.A.) at p. 876 that: "an instrument is altered in a material particular if the rights and obligations of the parties under it, if effect were given to it in its altered consideration, would be different from that which the law would imply if no alteration had taken place. ...

7 March 1991 Income Tax Severed Letter - Foreign Affiliates

Such considerations would not have been applicable to the subsection 5907(2.1) election. ...

7 April 1991 Income Tax Severed Letter - Redemption of Preferred Shares

XXX Evidentiary Considerations XXX If you have any questions in respect to this matter, we would be please to discuss them with you. ...

7 June 1991 Income Tax Severed Letter - Computation of Income from an Active Business of a Foreign Affiliate

By virtue of paragraph 95(2)(b) of the Act the income of a controlled foreign affiliate of a taxpayer from services is deemed to be income from a business other than an active business if the amount paid in consideration therefore is deductible in computing the income from a business carried on in Canada by any person in relation to which the affiliate is a controlled foreign affiliate. ...

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