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93 C.M.TC- Q. 4-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 The continuance of a corporation incorporated in Canada to the United States will not result in that corporation ceasing to be considered to have been created in Canada for purposes of Article IV of the U.S. ...

.- Q.64-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition The position in IT-125R3 respecting when a farm-out arrangement is not considered to be a disposition does not extend to the disposition of other property under agreements similar to farm-outs. ...

.- Q.47-- summary under Subsection 246(1) Summary Under Tax Topics- Income Tax Act- Section 246- Subsection 246(1) Where a Canadian corporation borrows funds from an arm's length lender and the Canadian corporation's non-resident parent guarantees the loan for no consideration, the Canadian corporation will not be considered to have received a taxable benefit from the parent. ...

.- Q.19-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) It is a question of fact whether a contribution of capital by a shareholder to a corporation to fund the acquisition of a capital asset can reasonably be considered to be made for the purpose of acquiring an interest described in s. 12(1)(x)(viii). ...

Profit- Shares Where the transfer of assets under section 85 followed by a sale of shares is simply an attempt to convert what would otherwise be an income gain to a capital gain, the profit on the sale of the shares will be considered to be "income. ...

.- Q.47-- summary under Subsection 37(1) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1) Disposition of a capital property a short time after its acquisition will be considered as evidence that the property was not acquired wholly for purposes of undertaking scientific research. ...

Annual Conference, Q. 4 (January- February 1993 Access Letter, p. 51)-- summary under Subsection 50(1) Summary Under Tax Topics- Income Tax Act- Section 50- Subsection 50(1) Given that the dictionary meaning of "insolvent" refers to incapability of paying debts, a corporation that has neither assets nor debt cannot generally be considered to be insolvent. ...

.- Q.48-- summary under Regulation 2902 Summary Under Tax Topics- Income Tax Regulations- Regulation 2902 A partnership which intends to exploit technology developed by it will not ne considered to derive "all or substantially all" of its revenue from the prosecution of scientific research or the sale of rights in or arising out of scientific research. ...

.- Q28-- summary under Subparagraph 251(2)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(2)- Paragraph 251(2)(b)- Subparagraph 251(2)(b)(i) partnership as person A partnership is considered to be a person when the computation of income at the partnership level is involved. ...

6 September 2000 Headquarters Letter RITS 25829-- summary under Residential Unit Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Residential Unit "Long-term care centres, nursing homes, long-term beds in hospitals, long-term health institutions, are also considered places of residence if most or all of the main factors listed above are indicative of being the individual's place of residence. ...