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7 September 1990 Income Tax Severed Letter - Tax consequences to the issuer and holder on the exercise by a holder of the exchange right in an exchangeable debenture

This tax deferral would not be necessary if a convertible debenture were considered an option with a pre-set price. ...

7 July 1991 Income Tax Severed Letter - Whether a taxable subsidiary of a non-profit organization will affect the non-profit organization's tax exempt status

Generally, an NPO which holds long-term investments does so to produce income from property or a business, and therefore it could not be considered to be operated exclusively for a purpose other than profit. ...

2 May 1984 Income Tax Severed Letter RRR38 - Tax implications to a Canadian corporation who has to make good on the guarantee of its foreign parent's bank loan

Notwithstanding the fact that no portion of the payments made by the Guarantor may be considered as interest insofar as it is concerned, the Guarantor would nevertheless be making payments to the Bank on the Guarantee "on account or in lieu of payment of or in satisfaction of interest" owing by the Parent to the Bank. 3. ...

7 October 1991 Income Tax Severed Letter - Deductibility of Civic Election Campaign Contributions

In our view, contributions to candidates in municipal elections are considered to be gifts. ...

7 April 1991 Income Tax Severed Letter - Widespread Farm-out

YOUR QUESTION You ask whether the implementation of the above arrangement will result in (i) Company A recognizing proceeds of disposition of a Canadian resource property, or (ii) the transactions falling within the administrative policy enunciated in paragraph 11 of Interpretation Bulletin IT-125R3 so that Company B would be considered to have incurred all of the costs of depreciable properties, exploration and development, as the case may be, with the attendant income tax results and Company A would not have to recognize proceeds of disposition of a Canadian resource property. ...

7 November 1990 Income Tax Severed Letter - Canada-U.K. Income Tax Convention

The opinions expressed herein are not advance income tax rulings and, in accordance with paragraph 21 of Information Circular 70-6R2 dated September 28, 1990, are not considered binding on the Department. ...

7 May 1991 Income Tax Severed Letter - Tax Exemption for Charitable Organization Resident in Japan and Carrying on Charitable Activities in Canada

In our view such taxpayers would not be considered "in the same circumstances" as is required by that paragraph. ...

7 July 1991 Income Tax Severed Letter - Alimony and Maintenance Payments

We also considered whether or not the payments might be deductible by the payer if they met the criteria set out in subsections 60.1(1) or (2) of the Act. ...

7 February 1991 Income Tax Severed Letter - Changes in the Terms of Debt Obligations

“The following changes in respect of the debt obligation itself (unless carried out pursuant to an authorizing provision in its original terms) are considered to be so fundamental to the holder's economic interest in the property that they almost invariably precipitate a disposition: (a) a change from interest-bearing to interest-free or vice- versa, (b) a change in repayment schedule or maturity date,...” ...

7 February 1991 Income Tax Severed Letter - Election of Agreed Amount on Transfer of Shares to Corporations and Capital Gains Exemption

The comments expressed are not advance income tax rulings and are not considered binding on the Department, in respect of any taxpayers, in accordance with paragraph 21 of Information Circular 70-6R2 dated September 28, 1990. ...

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