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After lengthy consideration of this problem, we are of the view that the discount on the promissory note charged back to the Canadian subsidiary is not subject to non-resident withholding tax under the provisions of 212(1)(b) of the Act. ...

In addition to the facts described in their letter, we have been told to assume that there was only one class of shares, there were no V-Day value considerations involved, and the transaction was not tax motivated. ...

It would also appear that a specific fact situation is under consideration. ...

8 February 1983 Income Tax Severed Letter RCT 5-4651 Unedited CRA Tags 85(1) Dear XXX: We are writing in response to your letter of December 2, 1982 wherein you requested our comments concerning subsection 85(1) elections where the transferee corporation cannot immediately issue the shares as part of the consideration for the transfer of property. ...

Since the issue you raise concerns tax policy, I have taken the liberty of forwarding a copy of your letter to the Honourable Don Mazankowski, Minister of Finance, for his consideration. ...

10 December 1981 Income Tax Severed Letter RCT 85-001 Unedited CRA Tags 85 Section 85 Preferred shares and section 85 transfer What is the position of the Department of National Revenue with respect to preferred shares given as consideration in a sale governed by section 85 of the Income Tax Act (Canada)? ...

However, since this issue is in respect of a completed transaction, we are submitting the matter for your consideration and reply. for Director Financial Industries Division Rulings Directorate ...

The language used suggests to us that the legislators gave no consideration to a corporation owning an interest in a group term life policy that covered more than one person with the result that the legislation is somewhat deficient here. ...

Where a taxpayer has disposed of property to a taxable Canadian corporation for consideration that includes shares of the capital stock of the corporation, we are of the view that a prior issuance of shares by the corporation for cash, in and by itself, would not constitute a business for the purposes of subsection 85(1.1) of the Income Tax Act (the Act). ...

Consequently, it would appear that the goodwill was transferred for consideration including shares and therefore meets the requirements of subsection 85(1) of the Income Tax Act. ...