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(SEE E9433136 & "Household Products Company Limited v. MNR", 64 DTC 164, Tax Appeal Board and Carland (Niagara) Ltd v MNR, 34 Tax ABC 386) (2) (a) The treatment of insurance and general scheme of the Act; life vs non-life. ...

The Employer is a registered charity under paragraph 149(1)(f) of the Income Tax Act (the “Act”) (Registration # XXXXXXXXXX). ...

Position: No Reasons: See detailed issued sheet for file control # 971764 XXXXXXXXXX 980710 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1998 Dear Sirs: Re: XXXXXXXXXX Advance Income Tax Ruling This is in reply to your letter dated XXXXXXXXXX requesting an advance income tax ruling on behalf of the above-referenced taxpayer. ...

The SRA would provide pension benefits in excess of the limits under the Plan described in paragraph 3(c) above, and would have the following attributes: The pension benefit payable under the SRA will be calculated as the amount determined under the following formula: benefit payable = A- B- C Where: Ais the annual pension benefit that would be payable on salary (not exceeding XXXXXXXXXX or such greater amount as may be determined from time to time by XXXXXXXXXX) under the Plan but for the limits imposed under the Act, as described in paragraph 3(c) above; Bis the annual pension benefit payable under the provisions of the Registered Plan; and Cis the pension benefit attributable to a "notional account" determined to be the aggregate of; (i) accumulated member contributions that would have been made under the Registered Plan on all salary up to and including $XXXXXXXXXX per year, XXXXXXXXXX to the effective date of the SRA, but for the limitations imposed under the Plan and the Act (as described in paragraph 3(d) above); (ii) interest thereon from the time that such contributions would have been made, had they been permitted under the Plan, calculated at the rate applicable to member contributions under the Plan and converted, using appropriate actuarial principles at the time of retirement, termination, death or disability, into an annual pension in the same form as the pension payable under the Plan. ...

" means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof. ...

Yours truly, XXXXXXXXXX for Director Financial Industries Division Income Tax Rulings Directorate Policy & Planning Branch ...

XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

Principal Issues: Will the shares of a corporation that is financing its XXXXXXXXXX % interest in a CCPC that will build and operate a XXXXXXXXXX be qualified investments for an RRSP under 4900(12)(a) of the Regulations? ...

Since XXXXXXXXXX % of the principal of the loan will be required to be repaid by the employee within the XXXXXXXXXX-year loan period, it is our view that there will be bona fide arrangements made for the repayment of the loan within a reasonable time. ...