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We trust you will give this request favourable consideration. Yours sincerely, C. ...

The matter is presently under consideration. We trust our comments are of assistance to you. ...

Eisner 613 957-2138 February 2, 1990 Re: 24(1) Advance Income Tax Ruling Request In your letter of January 2, 1990, you advised us that certain information, which we require in order to proceed with our consideration of your advance income tax ruling request, will not be available until June, 1990. ...

However, after careful consideration of the circumstances, it is regretted that a recommendation cannot be made for the remission of taxes paid as a result of the 24(1) The law restricting the purchase of an IAAC became effective after November 12, 1981. ...

The notable example related to drilling rigs, although another case which is under consideration is one involving consultants and space being available in the offices of the hiring party in Canada. ...

After careful consideration of the matters raised, 24(1) When the remission guidelines are not met, the remission process cannot provide relief from taxation beyond that already made available by parliament to all taxpayers under the Income Tax Act. ...

A holding company is formed wholly owned by the individual and the operating company shares are transferred in for consideration of common shares and debt equal to the cost base. ...

This matter has been brought to the attention of Current Amendments for their consideration. ...

15 January 1993 Income Tax Severed Letter 9236060- Prepayment of Debt Unedited CRA Tags 18(9.1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. 1993 Manitoba Institute/Bar Revenue Canada Round Table- Question 13 Author: Steve Tevlin Date: January 15, 1993 Document Type: Code 7 T236 #: 923606 Section of Act: 18(9.1) Question (a) Where a financial institution lender receives payments from different borrowers, in each case as consideration for a reduction in the rate of interest payable on a debt obligation or as a penalty or bonus payable by reason of the repayment of all of or part of the principal amount of a debt obligation, will the lender in calculating its income for subsequent years consider such payments on an individual loan basis or an aggregate basis? ...

The purpose of paragraph 84.1(1)(a) of the Act is to prevent an individual taxpayer from receiving, in certain circumstances, consideration (other than debt or shares of the purchaser corporation) in respect of a corporation's pre-1972 surplus. ...