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A loan is considered to bear a commercial rate of interest for purposes of this subsection if interest is charged on the loan at a rate not less than either the prescribed rate of Interest or the rate that would have been agreed upon between arm's length parties under similar circumstances at the time the indebtedness was incurred. ...

We are not in a position to comment on, the Pension Trust Funds documentation you submitted as the situation apparently concerns a proposed transaction involving an identified insurer and a specific Pension Plan and accordingly would most appropriately be considered through the mechanism of an advance income tax ruling as discussed in Information Circular 70-6R and the Special Release thereto (copies attached). ...

Jones will have to meet the same conditions noted above to be considered a qualified investment for the purposes of subparagraph 146(1)(g)(iv) of the Income Tax Act. ...

Under the circumstances, the interest earned on mortgages and notes receivable resulting from the sale cannot reasonably be considered to pertain to or by incident to the day-to-day management business previously carried on. ...

Where the debt or right to receive an amount has an amortized cost, that amortized cost will be considered to be the proceeds. ...

We understand the share structure of XXX is as follows: XXX Other relevant facts are as follows: XXX Our Views We confirm our earlier opinion, expressed in our letter dated February 11, 1988 to XXX that where the 90% share ownership test is met but the corporation has the right to redeem its preferred shares, it could, for uses of subparagraph 149(1)(d) of the Act, be considered that "a person other than Her Majesty in right of Canada or a Province or a Canadian municipality had during the period, a right under a contract, in equity or otherwise either immediately or in the future and either absolutely or contingently, to, or to acquire, shares or capital of that corporation. ...

You specifically asked that, where an annuitant has the option of paying the administration fees directly to the trustee or by a payment into the RRSP account which is subsequently used to pay the fees, would such a payment into the RRSp account be considered a contribution to a RRSP for which a receipt should be issued. ...

It is our position that an employee will be considered to have retired even though he may continue as a director at nominal compensation (see paragraph 4(a) of Interpretation Bulletin IT337R2 (“Retiring Allowances”) and paragraph 4 of ATR-12 (“Retiring Allowances”, October 27, 1986). 3. ...

With respect to your original reply to XXX we note that this was taken from our memo to you of September 22, 1989 which provided you with our opinion as to what the Department's position should be on the eligibility of B Corp Installment Receipts as investments for RRSPs in a case where an actual completed transaction was being considered. ...

Where a plan member is allowed to direct how his contributions will be invested, it is our opinion that a single trust, as contemplated, may not exist and each annuitant may be considered to have a separate trust governed by a separate plan. ...