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(b) Paragraph 81(1)(h) states in part: "... received directly or indirectly by the taxpayer... ...

To the extent that it relates to a past transaction you should contact the appropriate Tax Services Office of the Canada Customs & Revenue Agency (the "CCRA"). ...

XXXXXXXXXX states: "... if there were no agreement there would be no potential benefit and this issue would not arise. ...

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. ...

The Agreement states that the payments of this income were to include "all entitlements you may have under Company policy, common law, as well as any statutory entitlements to notice pay, severance pay, and vacation pay you may have under the Employment Standard Act ". 4. ...

However, we can offer the following general comments regarding the application of the Act to non-profit organizations and trusts: The Canada Customs & Revenue Agency's ("CCRA") view on some of the factors to consider when determining whether a club, society or association would qualify as a non-profit organization are contained in Interpretation Bulletin IT-496 entitled "Non-profit Organizations. ...

September 13, 2001 Toronto East TSO HEADQUARTERS Small/Med Business Audit Shaun Harkin, CMA Verification & Enforcement (613) 957-9229 Attention: Mike Bolton Trust and Pension Section 2001-008306 XXXXXXXXXX Health and Welfare Trust ("HWT") This is in reply to your memorandum dated May 4, 2001 in which you asked for our comments on the acceptability of the above named trust agreement, which accompanied your letter, as a HWT. ...

The response to question two at the 1993 Canadian Tax Federation Revenue Canada Round Table states in part: "... ...

We would note that comments in the above Technical Guide concerning eligible / ineligible assets of "systems" or "enhanced combined cycle systems" qualifying under paragraph (c) to Class 43.1, indicate that not all assets associated with Qualifying Equipment are considered eligible assets, i.e., not all of such assets should be considered "ancillary to" such equipment for purposes of subparagraph (a)(iv) to Class 43.1. ...

Principal Issues: Various issues on sojourning Position: see memo attached Reasons: see memo attached July 9, 2001 International Tax Directorate International Section Rene Fleming, Manager Tim Kuss Policies & Publications Section 957-2117 Policy and Programs Division Attention: Ved Arora 2000-004761 Paragraph 250(1)(a)- Sojourning in Canada You have requested our views with regard to certain issues raised by XXXXXXXXXX, regarding the applicability of paragraph 250(1)(a) to determine the residence status of certain airline pilots employed by a Canadian resident airline. ...