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A second issue on which you requested our opinion is whether a taxpayer would be considered to have disposed of a share of the capital stock of a corporation in the course of a reorganization of capital of the corporation where such taxpayer exchanges all of his shares of a particular class for shares of a different class of the corporation (the "exchanged shares") that have previously been authorized. ...

Assuming that the cash method farmer carries on the business of growing and selling this species of plants, it is our view that a cash basis farmer's growing crop of plants would, for purposes of subsection 85(1) of the Act, be considered inventory owned by the farmer. ...

Discussion The above concerns were considered and addressed in 1991 at the Deputy Minister level after the issue was raised by the Vancouver District Office. ...

In our view the main criteria to be considered in determining whether existing paragraph 146(5)(a) of the Act applies to a specific situation in a year is whether the employer has or may at some future time contribute to a pension plan on behalf of the employee in respect of the year. ...

Some of the items that would have to be considered are the purpose of the transaction, whether the trust agreements permit the proposed merger, etc. ...

However, in a situation similar to that mentioned in your memorandum, we have stated that the transfer of shares is considered to constitute a disposition of partnership property to which subsection 85(2) applies in the answer to Question 48 of the 1987 Revenue Canada Round Table. ...

The Queen [[1986] 1 C.T.C. 219] (86 DTC 6039), subsection 245(2) of the Act, is an independent taxing provision. consequently, a deemed payment assessed pursuant to paragraph 245(2)(b) of the Act, is considered in effect as being assessed pursuant to a separate paragraph of subsection 212(1) of the Act. ...

It is our opinion that generally a unit of certified feature film would be considered to be a property to which subsection 85(1) of the Income Tax Act could apply. ...

A proper request entails the provision of all related documents for our review as well as an identification of all of the specific provisions of the Act in respect of which the request is to be considered. ...

IV This is in reply to your letter of January 21, 1987, in which you were seeking confirmation of your understanding of the income tax treatment of payments arising out of an income averaging annuity contract (an "IAAC") for an individual considered to be a U.S. resident for the purposes of the 1980 Canada-U.S. ...