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30 April 1990 Administrative Letter 59276 F - Qualified Small Business Corporation Share

Each shareholder of OPCO will transfer his shares of OPCO to NEWCO for consideration comprising shares of NEWCO having a fair market value equal to the fair market value of the shares of OPCO so disposed of by him and will elect, jointly with NEWCO, to have the provisions of subsection 85(1) of the Act apply to the transfer. ... Each of the three individuals will transfer the shares of the HOLDCO owned by him to OPCO for sole consideration comprising shares of OPCO having a fair market value equal to the fair market value of the shares of the HOLDCO so disposed of by him and will elect, jointly with OPCO, to have the provisions of subsection 85(1) of the Act apply to the transfer. ...

31 May 1993 Administrative Letter 9312986 F - Permanent Establishment & Carrying on Business (4112-2-5)

.- Paragraph 26 of Interpretation Bulletin IT-270R2 states that: "A determination of the place where a particular business (or a part thereof) is carried on necessarily depends upon consideration of all the relevant facts, but has been stated in general terms to be the place where the operations in substance take place. ...

1 July 1997 Administrative Letter 7M16092 - NOTICE TO EMPLOYERS-MANITOBA FLOOD RELIEF PAYMENTS

Pour que le décret s'applique, les conditions suivantes devront être réunies:- vous devez accorder l'aide de façon volontaire;- vous ne devez pas accorder l'aide financière aux employés en raison de considérations liées à leur emploi, par exemple le rendement, la fonction, les années de service, etc.;- vous ne devez pas accorder l'aide financière en contrepartie de services rendus ou à rendre;- le montant d'aide financière ne sert pas à compenser l'employé pour la perte d'un revenu d'emploi. ...

24 November 1995 Administrative Letter 9527222 - WHETHER PAYMENTS ARE FOR "MAINTENANCE" OR CAPITAL

As it is our understanding that such enquiries would perhaps be better routed to your Division for consideration and action, we are directing our response to you. ...

30 August 1990 Administrative Letter 59796 F - Allocation of Partnership Income

Farmout The hypothetical situation appears to be similar to a widespread farmout arrangement whereby a farmee, Partner B, would acquire an interest in a farmor's, Partner A's, Canadian resource property and in consideration for such interest, Partner A would receive, inter alia, an interest in Partner B's depreciable property. ...

15 June 1993 Administrative Letter 9231896 F - Deductibility of Ontario Mining Tax in Computing Income

Revenue is broadly defined under the OMTA as the total consideration that is received or is receivable from another person for the Ontario-produced mineral substances or processed mineral substances sold. ...

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