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Should you have an actual case under consideration we suggest that you request a ruling. ...

Factors that we have considered in establishing whether particular shares were or were not acquired in the ordinary course of business are as follows: 1) the nature of the holder's activities; 2) the number and frequency of such share acquisitions by the holder; 3) whether the funds involved represent the initial capitalization of a new subsidiary or the provision of additional operating capital to a subsidiary, both of which would normally indicate permanent capitalization; 4) the terms of the shares acquired and their status as “term preferred shares” otherwise than by virtue of control of the issuer by specified financial institutions; and 5) whether the shares were acquired as consideration on the sale of a business or part of a business where the holder's business has not previously included such transactions. ...

We are now, after further consideration, of the opinion that the income of a foreign affiliate should only be accepted, for the purposes of subparagraph 95(2)(a)(i), as pertaining or being incident to the active business of a related foreign affiliate in very rare and unusual circumstances where the taxpayer substantiates that there is a direct connection between the income of the foreign affiliate and the active business of the related foreign affiliate. ...

An organization's status for purposes of paragraph 149(1)(l) of the Act would be determined on the basis of the facts and details respecting its organization and its actual activities and the GST election should not be a consideration. ...

Since this circular deals primarily with administrative policies and practices which are essentially the same as those described in the previous version, we have no specific comments to offer from a tax policy viewpoint. however, we do offer the following general observations for your consideration. 1. ...

As consideration for corporation A issuing shares to the public, corporation A issues additional shares to corporation A. ...

7 September 1990 Income Tax Severed Letter- Remission of tax Unedited CRA Tags none Subject: Request for Remission of Tax XXX Our Minister, the Honourable Otto Jelinek, has received a letter dated June 20, 1990 from XXX on behalf of XXX requesting consideration of relief of the XXX. ...

Instead, we would ask that you address your concerns to your local District Taxation Office for their consideration. ...

In determining whether an employee/shareholder is in receipt of a benefit in a particular taxation year consideration will be given to the premiums paid by an employee/shareholder, if any, under the policy and the premium cost for equivalent term coverage. ...

Any exceptions to the above position could only be considered on a case by case basis and after consideration of all of the relevant facts. ...