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7 September 1991 Income Tax Severed Letter - At-risk rules

Advance tax rulings will continue not to be available for such arrangements where one of the main reasons for the arrangement can reasonably be considered to be to circumvent the at-risk rules. ...

7 September 1990 Income Tax Severed Letter - Interpretation in a situation where bank debentures are converted to deposits payable on a fixed date and whether such conversion would constitute a disposition

Paragraph 7 of the bulletin lists several changes in respect of debt obligations which, when implemented, are considered to precipitate a disposition of the obligation. ...

7 July 1990 Income Tax Severed Letter - Inventory allowance on leased assets

In a situation wherein a company policy of the lessor would allow the lessee to purchase the leased asset from the lessor, the company policy, in and by itself, would not be considered an agreement unless the purchase option has been offered by the lessor and accepted by the lessee. ...

26 October 1983 Income Tax Severed Letter RRRR85 - Payment of expenses and carrying on a business

As stated in paragraph 4 of Interpretation Bulletin IT-206R, the sale of all fixed assets of a business is also not considered a mandatory requirement for the ceasing of a business if it can otherwise be established to have ceased. ...

7 July 1990 Income Tax Severed Letter - Interpretation of the term “trader or dealer in securities”

If the election is considered to be available only to investors, who would be entitled to the capital treatment in any case, no greater certainty is achieved and the election becomes almost meaningless. ...

1 May 1990 Income Tax Severed Letter RRRR281 - Application of subsection 146(5) to employer contributions to a pension plan

In our view the main criterion 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 an employee in respect of the year. ...

7 August 1990 Income Tax Severed Letter - Leveraged investments in U.S. real estate partnerships

In any case, it is our understanding that such a mortgage would not be considered a bona fide mortgage for U.S. estate tax purposes and may therefore be ineffective in reducing such taxes. ...

7 December 1982 Income Tax Severed Letter RRRR80 - Interpretation of subparagraph 95(2)(a)(i) of the Income Tax Act in the hypothetical situation

On the other hand, interest oh securities held for long-term investment would normally be categorized as income from property but could be considered to be income from an active business where it can be shown that there is a clear relationship to the active business carried on by the foreign holding company. ...

18 May 1990 Income Tax Severed Letter RRRR290 - Whether the certain purchased items, on hand at year end, are inventory for purposes of the mandatory inventory adjustment or the optional inventory adjustment

Specifically, you inquire whether the following purchased items, on hand at year end, will be considered inventory for purposes of the mandatory inventory adjustment in paragraph 28(1)(c) and for the optional inventory adjustment in paragraph 28(1)(b). • unapplied fertilizers- unapplied chemicals- fuel- parts for machinery- feed for livestock- seed grain- automobile gas purchased in bulk The term "inventory" as used in these paragraphs has the same meaning as it does throughout the Act. ...

7 September 1990 Income Tax Severed Letter - Non-resident withholding tax exemption

It was recommend that the transactions be completed and the matter be addressed to the relevant district office along with a request for a referral back of Rulings if it was still considered necessary to obtain a determination on the withholding issue described below. ...

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