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2006 Ruling 2006-0197501R3- Multiple-wing Butterfly-- summary under Distribution Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(1)- Distribution Vacant land of a distributing corporation used as a parking lot for a facility owned by a subsidiary, and vacant land owned by the distributing corporation for the purpose of constructing a facility, will be considered to be capital property and business property. ...

2006 Ruling 2005-0160481R3- Charitable Organization- Related Business-- summary under Related Business Summary Under Tax Topics- Income Tax Act- Section 149.1- Subsection 149.1(1)- Related Business Ruling that a charitable organization would not be considered to be carrying on an unrelated business as a consequence of it renting excess parking capacity in a parkade built to provide low-cost parking to members. ...

2004 Ruling 2004-006020-- summary under Paragraph 149(1)(c) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(c) Ruling that a First Nation would be considered a public body performing a function of government in Canada, so that income attributed (under s. 75(2) or payable (under s. 104(13)) to it by a personal trust settled by it would be exempt. ...

2004 Ruling 2004-008032-- summary under Paragraph 149(1)(c) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(c) S.149(1)(c) would apply to exempt income allocated to a First Nation band on a limited partnership interest held by it in a partnership engaged in fishing, given that the band would be considered to be a public body performing a function of government in Canada. ...

Any tax accounts, such as the balance of any RDTOH account or capital dividend account would not be considered to be property. ...

30 November 1996 Ruling 9716083- AMERICAN DEPOSITARY SHARES, OPTIONS-- summary under Paragraph (d) Summary Under Tax Topics- Income Tax Act- Section 204- Qualified Investment- Paragraph (d) American depositary shares would be considered to be shares for purposes of s. 7, as CRA previously had concluded that they were shares for purposes of s. 146(1). ...

30 November 1996 Ruling 9716083- AMERICAN DEPOSITARY SHARES, OPTIONS-- summary under Paragraph 7(1)(a) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(a) American depositary shares would be considered to be shares for purposes of s. 7, as CRA previously had concluded that they were shares for purposes of s. 146(1). ...

30 November 1996 Ruling 9706043- SURRENDER OF INCOME INTEREST-- summary under Subsection 106(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 106- Subsection 106(2) Where the income beneficiary of a family trust releases and surrenders all her interests in the trust, she will be considered to have disposed of her interests for no proceeds. ...

2003 Ruling 2003-0024203- LEASE OF EXCESS SPACE BY CHARITY-- summary under Paragraph 149.1(2)(a) Summary Under Tax Topics- Income Tax Act- Section 149.1- Subsection 149.1(2)- Paragraph 149.1(2)(a) A charitable organization would not be considered to be carrying on a business by virtue only of leasing excess space under a net lease. ...

CRA rules that the subsidiary is not considered to have assumed the parent's liabilities. ...