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16 May 1990 Internal T.I. 80347 F - Investment Tax Credit Entitlement

Short File No. 8-0347 SUBJECT: Re 24(1) Notices of Objection 1983 and 1984 We are writing in response to your memorandum of January 15, 1990 in which you have requested our further consideration and comments with respect to a memorandum we issued on January 13, 1989, to the Ottawa District Office. ...

3 August 1990 Internal T.I. 901059 F - Inclusion or Exclusion of Certain Reserves in Determination of Capital of Large Corporation

Upon the wind-up, the acquiring corporation increases the book value of the assets of the acquired corporation by the difference between the consideration paid for the shares of the acquired corporation and book value of those assets. ...

24 November 1989 Internal T.I. 58677 F - Association

Given this somewhat unusual outcome in the application of the New Rules, this matter will be brought to the attention of the Department of Finance for their consideration. ...

18 April 1990 External T.I. 59665 F - Butterfly Reorganizations - Exception to Deemed Capital Gain Provision

If, as part of the transactions, an amount is paid by the particular corporation to another corporation in consideration for that corporation assuming the obligations under the "take-or-pay" contract, the requirements of subsection 20(24) of the Act will not be satisfied since the particular corporation would not have included in its income the amounts previously received under that contract. ...

28 September 1990 External T.I. 74385 F - Requirements for Deductibility of Damages

Kirk (1990) A.C.588, a statutory provision under consideration provided for a tax on income arising rom any trade carried on in New South Wales or derived from lands of the crown and stated that no tax shall be payable in respect of income earned outside the Colony. ...

20 April 1990 Ministerial Correspondence 59404 F - Associated Corporations

The comments set out in this letter are of a purely general nature and do not take into account considerations that might arise in the context of a specific transaction. ...

13 August 1990 External T.I. 74820 F - Small Business Deduction - Amount of Business Limit

However, due to the fact that the words being interpreted by the court, i.e. the corporation, are different from those currently under consideration, the outcome of this case is not considered as a precedent in interpreting these words. ...

15 January 1992 Income Tax Severed Letter 9132125 - Capital Gains Exemption

It has no application whatever to individuals, and does not take into consideration any capital gain that might be realized by an individual on the disposition of the shares of a corporation which is subject to the application of subsection 55(2) of the Act. ...

29 July 1991 Income Tax Severed Letter 9104315 - Re: Subparagraph 212(1)(b)(vii)

Answer to Question 9 A definitive opinion in respect of a matter of this kind can only be formulated after a determination and consideration of all relevant facts. ...

28 July 1989 Income Tax Severed Letter AC738342 - 99-Year Leases - Abalone & Roe Herring Licences

This will involve a consideration of all the legal rights and obligations of the parties. ...

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