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21 August 2018 External T.I. 2018-0771811E5- 120.4 Excluded Shares-- summary under Paragraph (b) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares- Paragraph (b) 10% of votes and FMV tests can be satisfied on a collective basis Where a shareholder has non-voting common shares with a fair market value (“FMV”) equal to 20% of the total FMV of the corporation and “skinny” voting preferred shares having a nominal FMV but having 20% of the total votes of the corporation, would the shares be considered excluded shares assuming the tests in paragraphs (a) and (c) of the definition are met? ...

We have reconsidered our previous position with respect to the payment of such fees by the annuitant outside of the RRSP or RRIF trust and we are now of the view that the payment of such fees by the annuitant would not be considered a premium or gift contributed to the RRSP or RRIF. ...

3 January 1997 External T.I. 9639365- REIMBURSEMENT OF RRSP ADMINISTRATION FEES-- summary under Premium Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(1)- Premium contribution to plan to fund admin fees is a premium The Department briefly stated: [W]here the annuitant makes a payment to his or her RRSP trust as a contribution under the trust to be applied for the purpose of providing the annuitant with a "retirement income" (as defined in subsection 146(1) of the Act) on maturity, the payment is considered a payment of a "premium" as defined in subsection 146(1) … unless it is a payment excluded in the conclusion to that definition. … [A]dministration or trustee fees can also be paid directly by the annuitant outside the trust and that there is no deduction for such payments made after March 5, 1996. ...

Similarly, "the Department has previously opined that income derived by a corporation that carried on a business of extracting, processing and selling uranium and income derived by a corporation that carried on a business of extracting, processing and selling gold were considered to be from the sale of similar properties... since uranium and gold are both 'minerals' within the meaning of subsection 248(1) of the Act. ...

16 June 1997 External T.I. 9711005- SAFE INCOME/PART IV TAX-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) Any dividend paid by a payer corporation is considered to be paid first out of the safe income on hand attributable to the recipient corporation's shares of the payer corporation. ...

12 September 1997 Internal T.I. 9716457- WHETHER REQUIRED BY CONTRACT TO PAY EXPENSE-- summary under Paragraph 8(1)(h.1) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h.1) The requirement that the employee be required under the contract of employment to pay the motor vehicle expenses "may also be considered to have been satisfied where it was testedly understood by the employer and the employee that the employee pay the travel expenses. ...

26 September 1997 External T.I. 9722915- ROYALTY INCOME AS ACTIVE BUSINESS INCOME-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business income from copyrighted music "If a company is in the business of composing music, the income it earns with respect to its copyrighted music would generally be considered active business income.... ...

4 December 1997 External T.I. 9726425- MIC'S AND REAL ESTATE-- summary under Subsection 130.1(6) Summary Under Tax Topics- Income Tax Act- Section 130.1- Subsection 130.1(6) development or ancillary rental services are not part of investing undertaking "Where a corporation otherwise would have met all the conditions outlined in subsection 130.1(6) of the Act acquires real property either for rent or for development, the corporation would not be considered a MIC since the condition that the corporation must not manage or develop real property, as outlined above, would not be met. ...

Where a marina having foreshore water leases is required under the terms of the lease to own land contiguous with the foreshore lease, such land would be considered to be used in an active business because it is a condition precedent to the operation of the Marina. ...

The lender would be considered to have an equity interest if it was entitled to participation payments computed as a percentage of profits from the production with no cap, and there was clearly no connection between the estimated participation payments and the fair market value interest rate. ...