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22 May 1990 Income Tax Severed Letter RRRR289 - Review of Corporate Reorganizations Course Material — Lesson 5 Surplus Strips

However, pursuant to subsections 186(2) and (4), subject corp. can still be considered connected with purchaser corp. if persons who do not deal at arm's length with purchaser corp. control subject corp. ...

7 July 1990 Income Tax Severed Letter - Application of subsection 245(2) to hypothetical situations involving the immediate withdrawal of funds from a partnership by a partner who transferred property to the partnership on a tax-deferred basis pursuant to subsection 97(2)

Our Comments There would be many factors to be considered in making any determination on the application of GAAR to a particular case. ...

7 August 1990 Income Tax Severed Letter - Part I.3 tax on large corporations

Provided such expense cannot be considered to be reserves for accounting purposes we would agree with your conclusion that such differences should not be adjusted for in the calculation of capital pursuant to proposed subsection 181.2(3). ...

7 August 1991 Income Tax Severed Letter - Transfer of Funds from a U.S. or U.K. Pension Plan to a Registered Pension Plan and Vice Versa

., it is not in the employee's power to demand payment of the funds or roll the funds into another plan, the transfer would not be considered a taxable event. ...

7 June 1991 Income Tax Severed Letter - Deferred Salary Leave Plan

Pursuant to subparagraph 6801(a)(iv) of the Regulations, the Plan must provide that any interest or additional amounts that may reasonably be considered to have accrued for the benefit of the employee in a year must be paid in that year to the employee. ...

7 May 1991 Income Tax Severed Letter - Deferred Salary Leave Plan

A proper request entails the provision of all related documents for or 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. ...

7 March 1991 Income Tax Severed Letter - Deferred Annuity Plan

Accordingly, a situation in which a taxpayer withdraws some or all of his funds from an annuity in a lump sum could be considered to be a surrender and, therefore, a disposition of all or a part of his interest in the annuity as the case may be. ...

7 September 1991 Income Tax Severed Letter - Foreign Income Tax Paid by a Foreign Affiliate

The portion of the $2,316 that would need to be considered reasonably applicable to the 1991 FAPI TCG in order to eliminate Canadian tax in respect thereof would be $1,900 as this amount multiplied by the relevant tax factor for the purposes of paragraph 91(4)(a) produces a deduction equal to the 1991 FAPI TCG ($5,000). ...

7 November 1991 Income Tax Severed Letter - Dissolution as a Result of Amalgamation of Partnerhsip Business Carried on as Sole Proprietorship

On the other hand, even on the assumption that the response to the first question is yes, i.e. if Amalco was a member of the partnership before the partnership ceased to exist, Amalco would be considered to be all of the persons who were, immediately before the partnership ceased to exist, members of the partnership. ...

11 January 1990 Income Tax Severed Letter AC58980 - Taxation of Flexible Benefits

Whether a flexible benefits plan may be considered an "employee benefit plan" within the meaning of subsection 248(l) of the Act is a question of fact which would be determined once all the particulars of a situation were known. 11. ...

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