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This is in reply to your undated memorandum regarding
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Our Comments
Our comments follow the point order of your questions. 1.
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3. Whether or not a particular subsection 15(1) benefit could be considered a distribution of income is a question of fact. It does not automatically follow that a 15(1) income inclusion to a shareholder is the result of the corporation making its available to the shareholder. It could, however, if the corporation had profits which were appropriated by that shareholder or other shareholders.
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4. In our view the position in paragraph 20 of IT-432R which indicates that shareholders of a co-operative housing project would not be subject to a 15(1) benefit or to the provisions of paragraph 69(1)(b) because they receive less than fair market value rent
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We trust that our additional comments relative to this matter will be helpful.
E.M. WheelerChiefExempt Corporation SectionLegislative and Intergovernmental Affairs Branch