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8 December 1981 Income Tax Severed Letter RCT 85-075 F Unedited CRA Tags 85 RE:     Your memo of October 23, 1981 It is our opinion that in the situation which you described in your above-noted memorandum, the preference shares taken back as part of the consideration under a section 85 rollover would not be considered to be non-share consideration for the purpose of determining the transferor's proceeds of disposition. ...

It is our view that expenses paid by a predecessor corporation which have been accounted for by it as prepaid expenses (as outlined in Interpretation Bulletin IT-417) will be considered to be prepaid expenses of the amalgamated corporation This view is predicated on the amalgamation constituting an amalgamation within the meaning of subsection 87(1) of the Act. ...

As explained XXX in our telephone conversation of July 20, 1989 the issues involved in this case are presently being considered by officers of our Vancouver District Office, and we are therefore unable to comment on any aspects of the case at the present time. ...

Since, XXX seeks confirmation that a director may be considered as the trustee of a DPSP in circumstances that do not seem to fit your administrative rule outlined in paragraph 18(a) of Information Circular 77-IR3 we request that you review such circumstances and respond to her directly. ...

It is our opinion that as long as the deferred annuity meets the requirements of subparagraph 146(1)(i.1) of the Income Tax Act (the "Act") and is purchased from a person licensed or otherwise authorized under the laws of Canada or a province to carry on in Canada an annuities business, it would be considered a qualified investment for the purposes of subparagraph 146(1)(g)(iii) of the Act. ...

Application of 85(4) and treatment of gain and loss relating to foreign exchange. 1. 85(4) does not apply since Canco could be considered to have disposed of capital property to a corporation. 2. ...

In addition the payments could not be considered a scholarship. XXX ...

After discussing this issue with officials from the Department of Finance, we are taking the position that if the aforementioned mutual funds conform with the redemption requirements of the Ontario Securities Commission, they will be considered to have met the redemption requirements in subparagraph 108(2)(a)(i). ...

In calculating an individual's cumulative gains limit for purposes of determining the capital gains deduction available to him for any given year under section 110.6 of the Act, the individual's CNIL must be considered in the calculation. ...

7 August 1990 Income Tax Severed Letter- Refusal to issue an advance income tax ruling Unedited CRA Tags none Subject: XXX We recently considered an advance income tax ruling request (copy attached) XXX While we refused to rule on the proposed transaction described in the ruling request, it is possible that XXX and XXX may proceed with the same or similar transaction without an advance income tax ruling. ...