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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. ...

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

In our view, training benefits (including tuition, allowances & books) provided to individuals which are funded under the EI Act are taxable under paragraph 56(1)(r) of the Income Tax Act (the "Act"). ...

Principal Issues: Whether travel expenses & expenses of new accommodations to facilitate obtaining medical care/ instruction for a dependant who has received a cochlear implant qualify for the medical expense tax credit Position: Expenses are not qualifying medical expenses. ...

The consulting income was received from a corporation XXXXXXXXXX % owned by the taxpayer's XXXXXXXXXX. ...

Income Tax Convention (the " Convention"). In general terms, Article XVII of the Convention provides that pension payments arising in the U.K. that are paid to a resident of Canada will only be taxable by Canada. ...

October 7, 2003 XXXXXXXXXX HEADQUARTERS Verification & Enforcement Division Randy Hewlett, B.Comm XXXXXXXXXX Tax Services Office 613-957-8973 2003-003794 Deductibility of 20(1)(m) Reserve- Software Maintenance Plans We are writing in response to your memorandum of September 5, 2003, wherein you asked for our opinion on the deductibility of a reserve by XXXXXXXXXX (the "Taxpayer") under paragraph 20(1)(m) of the Income Tax Act (the "Act") in respect of a software maintenance plan. ...

November 20, 2003 XXXXXXXXXX HEADQUARTERS Verification & Enforcement Division Randy Hewlett, B.Comm. ...

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

The fact that a full-time employee does not deal at arm's length with the proprietor would not disqualify the plan, provided that such employee is receiving coverage as an employee and not because of the relationship with the proprietor / employer. ...