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2004 Ruling 2004-0067771R3- Irish Common Contractual Fund-- summary under Subsection 104(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(1) Irish common contractual fund Ruling that an Irish Common Contractual Fund would be considered to constitute a co-ownership arrangement. ...

2002 Ruling 2001-0108483- PENSION FUND CORPORATION-- summary under Subparagraph 149(1)(o.2)(iii) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(iii) participating bond A participating bond that is permitted under the PBSA would be considered to be an investment allowed within the meaning of s. 149(1)(o.2)(iii)(A). ...

1999 Ruling 9920603- NON-RESIDENT- CARRYING ON BUSINESS IN CDA-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) Ruling that a Canadian company engaged by a non-resident fund manager to provide accounting and clerical services in Canada would not thereby cause the fund or its manager to be considered to be carrying on business in Canada. ...

1999 Ruling 9920603- NON-RESIDENT- CARRYING ON BUSINESS IN CDA-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) Ruling that a Canadian company engaged by a non-resident fund manager to provide accounting and clerical services in Canada would not thereby cause the fund or its manager to be considered to be carrying on business in Canada. ...

2009 Ruling 2009-0308961R3- Principal Purpose of Business-- summary under Investment Business Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Investment Business A CFA ("CFA1") which has been developing IP, manufacturing products for distribution by affiliates and employing more than five-full time employees will not be considered to have commenced carrying on an investment business by virtue of subcontracting out the maufacturing work to related an unrelated parties and elininating its workforce, notwithstanding its licensing of some of its IP to related persons. ...

2007 Ruling 2007-0245281R3- windup of income trust on sale of assets:3rd party-- summary under Subsection 104(21) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(21) trustees making filings on behalf of terminated fund Ruling that following the redemption of all the outstanding units of an income fund, any document that the fund is required to file under the Act will be considered to have been filed by the fund on the date that it is filed by its trustees. ...

2005 Ruling 2005-0133041R3- Investors not dealing non-arm's length-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) In the context of an issue as to whether shares of a non-resident corporation were taxable Canadian property, CRA ruled that the winding-up of the corporation and related transactions by a group of shareholders would not, by itself, cause them to be considered to be not dealing arm's length with each other or with the corporation and its subsidiaries. ...

21 December 1995 Ruling 940411 [tenant pays for improvements on lease termination]-- summary under Subsection 182(1) Summary Under Tax Topics- Excise Tax Act- Section 182- Subsection 182(1) tenant pays for improvements on lease termination An amount payable by a tenant on the termination of a lease, equal to the amortized value of leasehold improvements, would not be considered to be subject to s. 182 but, instead, would be regarded as consideration for a supply by the tenant of such improvements. ...

1996 Ruling 961368-- summary under Subsection 18(9.1) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(9.1) With respect to a situation where a taxable Canadian corporation made an offer to purchase at a premium outstanding notes that were eligible for the exemption under s. 212(1)(b)(vii), RC ruled that provided that the premium "cannot reasonably be considered to have been made in respect of the substitution of the Notes into another debt obligation", the premium will be exempt. ...

1996 Ruling 961368-- summary under Subparagraph 212(1)(b)(vii) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Subparagraph 212(1)(b)(vii) With respect to a situation where a taxable Canadian corporation made an offer to purchase at a premium outstanding notes that were eligible for the exemption under s. 212(1)(b)(vii), RC ruled that provided that the premium "cannot reasonably be considered to have been made in respect of the substitution of the Notes into another debt obligation", the premium will be exempt. ...