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Although we have not previously considered a situation where debt holders have a contractual obligation to purchase shares (that are prescribed securities within the meaning of Regulation 6802) of the debtor within 5 years from the date of issue of the debt and the purchase price for the shares could be satisfied by surrendering to the issuer debt having an equivalent principal amount, it appears to us that the debt holder’s rights under the terms of the debt could not be said to be a right to convert or exchange the obligation for a prescribed security but rather is a right to use the obligation to pay for a mandatory purchase. ...

Amounts received out of an EPS will also not fall within the provisions of paragraph 56(1)(a) of the Act as superannuation or pension benefits except to the extent the EPS can be considered to be a superannuation or pension plan. ...

On the other hand, if the property is sold for more than it is worth, the excess will be considered to be a gift or a contribution to the RRSP and could be subject to Part X.1 tax. ...

Leung (613) 957-2115 Attention: XXXXXXXXXX August 28, 1998 Dear Sirs: Re: Foreign Affiliate We are writing in response to your letter of August 14, 1997 in which you requested our opinion as to whether a U.S. limited liability corporation in the following hypothetical situation would be considered a foreign affiliate of a Canadian corporation. ...

A second estate freeze is now being considered where the corporation will exchange the new common shares issued in (1) above for preferred shares. ...

An association, in order to be considered "approved" for the purposes of section 37 of the Act, must receive written approval from our Minister. 2. ...

We have also considered the provision of paragraph 118.2(2)(o) of the Act which deals with amounts paid for laboratory, radiological or other diagnostic procedures or services prescribed for a patient by a medical practitioner or dentist. ...

You seek further clarification on how Revenue Canada has determined that financial assistance for training provided to Employment Insurance (EI) clients under the New Brunswick Skills Loans and Grants program are considered taxable to the recipients. ...

An association, in order to be considered "approved" for the purposes of section 37 of the Act, must receive written approval from our Minister. 2. ...

You provide the following set of hypothetical facts. 1) Newco, a corporation resident in the United Kingdom, issues a debt instrument (the “Newco Debt”) to its Canadian parent (“Canco”) as consideration for shares of a related United Kingdom company. 2) The interest on the Newco Debt is not deductible in computing taxable income for United Kingdom income tax purposes. 3) The interest on the Newco Debt, when paid will be considered a distribution of a dividend for United Kingdom tax purposes which requires the payer (Newco) to withhold and remit advance corporations tax (“ACT”). ...