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As stated in paragraph 1 of IT-85R2, in order to qualify as a Health & Welfare Trust, the benefit programs funded through the trust must be restricted to one or more of the following plans: a) a private health services plan, b) a group sickness or accident insurance plan, or c) a group term life insurance police. ...

Comments With regard to your first question, subsection 85(6) of the Act requires that an election made under subsection 85(1) of the Act "... be made on or before the earliest of the days on or before which any taxpayer making the election is required to file a return of income pursuant to section 150 of the Act for the taxation year in which the transaction to which the election relates occurred. ...

., using an appropriate per-kilometre rate applied to all business kilometres driven by the employee), that is not otherwise “deemed” an unreasonable allowance [subparagraphs 6(1)(b)(x) & (xi)], then deductions at source from the allowance would not be required. ...

In particular, you asked whether the deeming provision in the postamble of section 8600 of the Regulations, which reads, in part, "... where a corporation's taxable income for a taxation year is nil, it shall, for the purposes of this section, be deemed to have a taxable income for that year of $1,000" applies to both items C and B or only item C in the algebraic formula in section 8600 of the Regulations. ...

Holloway Toronto, Ontario (613) 957-2104 Attention: XXX March 9, 1992 Dear Sirs: Re: Paragraph 149(1)(1) of the Income Tax Act (the “Act”) & IT496 This is in reply to your letter dated December 23, 1991, requesting our interpretation in respect of the activities of your client the XXX and whether a corporation owned by the XXX qualifies as an non-profit organization as defined in paragraph 149(1)(1) of the Act. ...

XII RULINGS TAX SEMINAR CENTRAL REGION OCTOBER 14 & 15, 1992 ROYALTIES EXEMPTION- MEANING OF IN RESPECT OF PRODUCTION OR REPRODUCTION Subparagraph 212(1)(d)(vi) exempts certain copyright related payments in respect of the production or reproduction of any literary, dramatic, musical or artistic work. ...

Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information In addition to Information Circular 70-6R2 and IT-393R, we have attached the 1991 General Tax Guide and Return Federal Income Tax: " Non-residents and deemed residents of Canada" and the 1991 Supplementary Guide: "Rental Income Tax Guide" for your information. ...

7 October 1992 Income Tax Severed Letter 9229926- RRSP Home Buyers Plan Unedited CRA Tags 146.01 October 7, 1992 Business & Property Income Deferred Income and Exempt Organizations Section Plans Section Business and General Division Financial Industries Division Attention: Ernie Wheeler D. ...

TABLE RONDE SUR LA FISCALITÉ FÉDÉRALE APFF- CONGRES 1992 Question # 54 SUJET: MONTANT NÉGATIF Revenu Canada, Impôt peut-il indiquer sa politique administrative concernant l'application de l'article 257 de la Loi aux différents articles de la Loi qui ne contiennent pas de "formules algébriques" tout en contenant, par ailleurs, une méthode de calcul. ...

"... may reasonably be considered to have been made in respect of the extension of the terms of or substitution or conversion of a debt obligation... ...