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April 29, 1998 Federal Provincial Relations HEADQUARTERS & First Nations D. ...

Jim Wilson Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch- 6- ...

In particular, subparagraph 12(1)(x)(ii) through (iv) would bring into income amounts received by a taxpayer from a government that "... can reasonably be considered to have been received (iii) as an inducement, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of inducement, or (iv) as a refund, reimbursement, contribution or allowance or as assistance, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of assistance, in respect of (A) an amount included in, or deducted as, the cost of property, or (B) an outlay or expense". ...

Following the decision in the Williams case and as a result of a letter issued by the Department on December 29, 1992, which was followed up with considerable input from the Indian community, the Department has developed " INDIAN ACT EXEMPTION FOR EMPLOYMENT INCOME DETAILED GUIDELINES" which were released on December 15, 1993. ...

Holloway Office (613) 957-2104 Trusts Section Attention: Vince O'Neill 952803 Estates & Trusts Group Subsection 105(1) of the Income Tax Act-XXXXXXXXXX This is in reply to your memorandum dated October 24, 1995, concerning the applicability of subsection 105(1) to the above named taxpayer. ...

Bowen Tax Avoidance & International Bruce Reed, Team Leader Attention: Earl Ducksworth 953076 XXXXXXXXXX Disposition of a remainder interest in real property We are writing in reply to your memorandum dated November 22, 1995, wherein you requested our comments on the calculation of a capital gain arising from the disposition of a remainder interest in farm land. ...

XXXXXXXXXX En 1990, l'allocation hebdomadaire fixée par le décret O.C.Q. versée aux employés admissibles était de 285 $. ...

Cette définition prévoit, entre autres, à l'alinéa 118.2(2)b) des frais payés à titre de rémunération d'un préposé à temps plein pour une personne qui aurait eu droit au crédit d'impôt pour déficience mentale ou physique alors que l'alinéa 118.2(2)b.1) vise des frais payés à titre de rémunération pour les soins de préposé fournis à l'égard d'une personne qui aurait eu droit au crédit d'impôt pour déficience mentale ou physique et ce, jusqu'à concurrence de 5 000 $. ...

. ' used in paragraph 1204(1)(b)(ii) of the Regulations. In Gunnar Mining, the Court did not use the principle later used in Irving Oil and Munich Reinsurance (discussed below) of examining the origin of the interest earning funds or what alternate use the funds could have been put to, to determine whether the interest income was 'income derived from a mine.' In Gunnar Mining the Court noted that although the short term investments originated from mining activities, once invested, interest earned on these investments would not be considered as "income derived from a mine. ...

The Court then reasoned [p. 5302 & 5303]: Unlike the British Mexican case in which it was an express term of the agreement that the sum remitted should be applied by the debtor to reduce the amount shown in its books in respect of its assets to a figure more nearly representing the present value thereof, the remission in the present case seems to have been made to allow respondent to make the profit which it had anticipated making on the sale of the oxo-alcohol at the original price, and that Esso International Inc., although not obliged in any way to make the remission, did have an indirect interest in assisting the respondent company in this way. ...