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For example, we note that the wording in Exhibits 5 and 6, which you included for comparison, use the words "... owner assigns and conveys" and "hereby conveys, assigns, transfers and assents", respectively, in respect of conveyances. ...

Principal Issues: can a disability plan to which the employer has contributed be converted to an employee pay all plan as originally intended-issue of retroactive changes and what constitutes a new plan as opposed to a continuation of an existing plan (where the liability for premiums has been shifted from employer to employees) Position:-cannot retroactively change the plan & it is a question of fact as to whether a plan amendment creates a new plan-the existing plan will be a plan which is subject to 6(1)(f) even if the plan documentation indicates otherwise because the employer did make contributions to it even if that was not the intent Reasons: question of fact to be determined by TSO or a ruling A. ...

Raisons POUR POSITIONS ADOPTÉES: i)Dossier # 920366. ii)Question de fait. 5-953023 XXXXXXXXXX Philip Diguer A l'attention de XXXXXXXXXX Le 29 janvier 1996 Mesdames, Messieurs Objet: Avantages conférés aux employés La présente est en réponse à votre lettre du 13 novembre 1995 par laquelle vous nous demandez notre opinion concernant l'objet mentionné en titre. ...

Yours truly, Chief Financial Institutions Section Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

Based on the limited information available to us, it would appear that these workers fall into the category of employees who are ordinarily required to carry on the duties of their employment "... in different places". ...

March 28, 2003 Summerside Tax Centre HEADQUARTERS E & A S.Parnanzone Mr. ...

We have reviewed the list of reasons for the payment of Subsidies listed on the blank "Subsidy Agreement- Terms & Conditions" included with your letter and note that payments for many of the items listed would be excluded from reporting on a T5007 because of the exclusions in subsection 233(2) of the Regulations listed above. ...

". Paragraph 126(6)(a) states that "the government of a country other than Canada includes the government of a state, province or other political subdivision of that country;... ...

The Supreme Court of Canada found in Savage (83 DTC 5409) and Nowegijick (83 DTC 5041) that the words "in respect of" are "... of the widest possible scope. ...

Principal Issues: Does Bco, a Japanese company, dispose of its assets, including its shares of Cco (a "taxable Canadian corporation" in the oil & gas business in Canada), if Bco merges with Aco (another Japanese company that is Bco's parent) and the corporate law in Japan is of a "continuation type", as described in The Queen v. ...