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Rulings Directorate Discussion and Position Paper on Motion Picture Films and Video Tapes as Tax Shelters, Version 29/3/93 930501 (C.T.O. "Motion Picture Films - C.C.A.") -- summary under Subsection 43(1)

Although the issue is considered to be arguable, RC will consider the proceeds of disposition of the interest to be equal to the amount of the liability converted. ...

2012 Ruling 2011-0431891R3 - XXXXXXXXXX -- summary under Fully exempt interest

The ruling summary states that: The interest paid is considered to be 'fully exempt interest' as defined in subsection 212(3) of the Act for the purposes of subparagraph 212(1)(b)(i) of the Act. ...

2013 Ruling 2013-0496351R3 - Loss Consolidation -- summary under Subsection 88(1.1)

"For this purpose, Lossco will not be considered to have been wound up until after it has been formally dissolved. ...

2012 Ruling 2011-0403291R3 - Treaty exempt sale -- summary under Disposition

Ruling that the partners will not be considered to have disposed of all or part of their partnership interests in that partnership as a result of the distribution. ...

2018 Ruling 2017-0723421R3 - Creation of a new Mutual Fund Trust -- summary under Section 253.1

Ruling that s. 253.1 will apply such that the acquisition of the limited partnership interest in the LP by the Trust will not, in and of itself, cause the Trust to be considered to be carrying on the business of the limited partnership for the purposes of s. 132(6)(b). ...

30 November 1996 Ruling 9709793 - QUALIFIED FOR DISTRIBUTION TO THE PUBLIC -- summary under Paragraph 4803(2)(a)

For purposes of calculating the number of beneficiaries of the unit trust, each annuitant of a group RRSP will be considered a beneficiary of the unit trust. ...

2004 Ruling 2003-0054221R3 - "investing of funds" and guarantees -- summary under Subparagraph 132(6)(b)(i)

CRA ruled that the REIT’s guarantee of mortgages on such properties (without any fee being charged and provided in order to to obtain insurance on the mortgages) would not be considered an undertaking other than investing funds in property. ...

2004 Ruling 2004-0084311R3 - Incorporating a Partnership -- summary under Personal Services Business

Ruling that provided that partners providing professional services to Newco through contracting companies would not, but for the existence of the contracting companies, be officers or employees of Newco in respect of those professional services, the contracting companies will not be considered to be carrying on personal services businesses. ...

2001 Ruling 2001-0090213 - Tax loss consolidation -- summary under Subsection 245(4)

If such transactions resulted in a non-capital loss to Subco, they would be considered to be abusive as they effectively would permit the refreshing of non-capital losses of the parent. ...

2001 Ruling 2001-0077753 - DIRECTORS FEES & STOCK OPTIONS -- summary under Paragraph 7(1)(a)

When the stock options are exercised, the partnerships will be considered to have received business income equal to the excess of the fair market value of the underlying securities at the time of exercise over the exercise price. ...

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