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Warrants would normally be considered as rights to shares rather than shares themselves. ...

The comments expressed are not advance income tax rulings and are not considered binding on the Department, in respect of any taxpayer, in accordance with paragraph 21 of IC 70-6R2 Yours truly, for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch ...

A statutory definition of "business" for purposes of the ETA would not be considered relevant to making this determination. ...

Interpretation Bulletin IT-233R, which is currently being revised, will likely contain the Department's views on when a transaction would be considered to be a disposition of property, rather than a lease, under the Act.  ...

The submission of this information should result in the tax consequences of the proposed transactions having been thoroughly considered and should make a review of a draft ruling unnecessary. ...

10 June 1991 Internal T.I. 903377 F- Share Purchase Arrangements on Employment Termination Unedited CRA Tags n/a Dear Sirs: Re:  Share Purchase Arrangements on Employment Termination This is in reply to your letter dated November 20, 1990 in which you requested our views as to whether amending a shareholders agreement would be considered to be a benefit to an employee/shareholder.  ...

The subsequent payment of the life insurance proceeds to the trust, on the death of the parent, would not be considered to be a contribution. ...

The comments in paragraphs 9 & 10 of IT-436 were not included in IT-436R as it was considered that they would have limited application since subsection 20(8) and subparagraph 40(1)(a)(iii) of the Act had been amended to restrict the time limit to 36 months and 5 years respectively for the deduction of reserves. ...

We have considered the arguments put forth in your letter and agree that the comments in our letter of April 17 may not be correct in all situations.  ...

It is our opinion that the payment of an interest bonus into an RRSP does not contravene the provisions of paragraph 146(2)(c.4) of the Income Tax Act and therefore, no advantage will be considered to have been extended to the annuitant of the RRSP by such a payment. ...