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La Loi canadienne sur la santé définit «medical practitioner» (médecin) comme (traduction) « une personne légalement autorisée à exercer la médecine au lieu où elle se livre à cet exercice». ...

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. ...

October 15, 1996 Regina Tax Services Office Head Office Estates & Trusts Income Tax Rulings and Interpretations Directorate Attention: Mr. ...

The definition of "cumulative gains limit" and the relevant portion of the "annual gains limit" read as follows: ""cumulative gains limit" of an individual at the end of a taxation year means the amount, if any, by which (a) the total of all amounts each of which is (i) the amount determined in respect of the individual for the year or a preceding taxation year ending after 1987 for A in the definition "annual gains limit", or (ii) the amount determined in respect of the individual for a preceding taxation year ending after 1984 and before 1988 under paragraph (a) of the definition "annual gains limit" as it read in its application to those years exceeds the total of (b) all amounts each of which is (i) the amount determined in respect of the individual for the year or a preceding taxation year ending after 1987 under paragraph (a) or (b) of the description of B in the definition "annual gains limit", (ii) the amount determined in respect of the individual for a preceding taxation year ending after 1984 and before 1988 under paragraph (b) or (c) of the definition "annual gains limit" as it read in its application to those years, or (iii) an amount deducted under paragraph 3(e) by the individual for the individual's 1985 taxation year, (c) all amounts deducted under this section in computing the individual's taxable income for a preceding taxation year, and (d) the individual's cumulative net investment loss at the end of the year;" The description of "B" in the formula A- B found in the definition of "annual gains limit" reads in part, as follows: "B is the total of (a) the amount, if any, by which (i) the individual's net capital losses for other taxation years deducted under paragraph 111(1)(b) in computing the individual's taxable income for the year exceeds (ii) the amount, if any, by which the amount determined in respect of the individual for the year under paragraph 3(b) in respect of capital gains and capital losses exceeds the amount determined for A in respect of the individual for the year, and b) all of the individual's allowable business investment losses for the year; " (emphasis added is ours) Note that the definitions of "annual gains limit" and "cumulative gains limit" as they read prior to the 1993 amendments would yield the same result provided that none of the gains or losses in question relate to non-qualifying real property. ...

& 2. above is "...for purposes of this paragraph..." (252(4)(a)) and not the Act as a whole; therefore, only for purposes of spousal determination. ...

Les deux scénarios en question sont les suivants: 1er scénario: un particulier participe au RAP, retire la somme de 7 500 $ de son régime enregistré d'épargne-retraite ("REER") pour l'achat d'une habitation le 25 février 1994 et fait faillite le 7 novembre 1994 après avoir rencontré toutes les conditions de participation au RAP. ...

Accordingly, you have asked whether, in such a situation, a WLRP could be provided through the establishment of a health & welfare trust. ...

.): (...) it is my opinion that a purchaser has acquired assets of a class in Schedule B when title has passed, assuming that the assets exist at that time, or when the purchaser has all the incidents of title, such as possession, use and risk, although legal title may remain with the vendor as security for the purchase price as is the commercial practice under conditional sales agreements. ...

We have informed the Department of Finance ("Finance") of this circularity problem, however, should you wish to pursue this matter we would suggest that you write to Finance at the following address: Tax Policy & Legislation Branch Department of Finance 140 O'Connor Street L'Esplanade Laurier 17th Floor, East Tower Ottawa, Ontario K1A 0G5 In general subsection 110.6(8) of the Act is an anti-avoidance rule enacted to prevent the conversion of dividend income into exempt capital gains. ...

Principal Issues: self-administered phsps & the rules relating to c/f, eligible expenses, etc. ...