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7 June 1989 Income Tax Severed Letter 15

DEPARTMENT'S POSITION AS INDICATED IN OUR RESPONSE TO QUESTION 50 AT THE 1986 REVENUE CANADA ROUND TABLE, IT IS THE DEPARTMENT'S VIEW THAT AN INTEREST IN A PARTNERSHIP IS NOT CONSIDERED TO BE AN INTEREST IN ITS UNDERLYING ASSETS FOR PURPOSES OF SECTION 85 OF THE ACT. ...

7 August 1990 Income Tax Severed Letter - Interpretation of the phrase “ actively engaged” in the definition of the term ”share of the capital stock of a family farm corporation” in paragraph 70(10)(b)

This is in contrast to a passive shareholder or investor who would not be considered to be “actively engaged”. ...

7 March 1991 Income Tax Severed Letter - Retirement compensation arrangement — letter of credit

It is our opinion that, in a situation such as the one you described in your letter, that it is the fair market value of a letter of credit acquired by an employer and transferred to a trustee for the benefit of an employee or employees which would be considered as a contribution by the employer to an RCA and which would be subject to the refundable tax under Part XI.3 of the Income Tax Act at the time of the contribution. ...

7 December 1990 Income Tax Severed Letter - Advance payments on grain inventory

As a result advance payments received, by farmers on their undelivered grain, under the Prairie Grain Advance Payment Act and the Advance Payments for Crops Act will be considered loans and not treated as income in the fiscal period received. ...

7 November 1991 Income Tax Severed Letter - Implications of different definitions of “business” in the Excise Tax Act and the Income Tax Act

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

7 September 1991 Income Tax Severed Letter - Non-resident withholding tax

Assuming that it is an avoidance transaction, it would be considered to be a misuse of subparagraph 212(1)(b)(vii) of the Act and, for that reason, would be subject to subsection 245(2) of the Act. ...

7 June 1991 Income Tax Severed Letter - Employee benefit plans and retirement compensation arrangements funded through the acquisition of life insurance policies

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. ...

7 April 1991 Income Tax Severed Letter - Tax implications of a payment of an interest bonus into a registered retirement savings plan

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. ...

7 November 1990 Income Tax Severed Letter - Non-resident withholding tax exemption on interest

Assuming that it is an avoidance transaction, it would be considered to be a misuse of subparagraph 212(1)(b)(vii) and, for that reason, would be subject to subsection 245(2). ...

7 November 1991 Income Tax Severed Letter - Whether a contribution to the capital of a corporation by a shareholder for the purpose of funding the acquisition of a capital asset included in income

It is a question of fact whether a contribution of capital by a shareholder to a corporation can reasonably be considered to be made for the purpose of acquiring such an interest. ...

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