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Employees would pay 100 % of the premiums on the "top-up" LTD plan. ...

We understand that copies of technical interpretation # 2003-0028025 and Income Tax Technical News- Number 19 were sent to you on November 30, 2005. ...

Principal Issues: whether the child of a spouse of a taxpayer continues to be the child of the taxpayer after the death of the spouse if 252(1)(c) is the only reason by which the child would be a child of the taxpayer Position: no Reasons: while some of cases decided on 252 when the reference was to daughter-in-law or son-in law found that the relationship continued after the death of the spouse of the daughter-in-law or son-in-law, the def'n of spouse is important for the def'n of child & as stated in para 31 of IT-249R3, the child relationship must exist at the time of the death of the owner of the farm which is being "rolled over". ...

Note that if a payment is a "periodic pension payment" as defined in ITCIA, then our position is that it is not in full satisfaction of all future entitlements & is therefore exempt pursuant to paragraph 1 of Article; however, a payment out of an unmatured RRSP is excluded from def. of "periodic pension payment". ...

Principal Issues: whether binding and laminating are m & p Position: they may be, but the goods must be for sale or lease Reasons: 125.1(3) contains requirement that goods be for sale or lease 970383 XXXXXXXXXX Denise Dalphy (613) 957-9231 Attention: XXXXXXXXXX February 21, 1997 Dear Sirs: Re: Manufacturing or Processing Goods for Sale or Lease This is in reply to your facsimile transmission of February 11, 1997 wherein you requested our opinion on the application of the above-referenced subject. ...

Yours truly, for Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

A detailed analysis of the issues involved can be found in our submission to the Review Committee dated May 6, 1997- document # 951901. ...

Yours truly for Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

Reasons: The fossil fuel used by the steam producer\vendor would be allocated to the electrical energy & steam produced by the steam producers\vendors Class 34 equipment. ...

Toutefois, lorsque le REER utilise les sommes obtenues du dividende pour acheter d'autres actions d'une corporation étrangère, ceci peut avoir pour conséquence que le coût indiqué des actions étrangères dépasse, après le ré-investissement, 20 % du coût indiqué de tous les biens détenus par la fiducie régie par le REER. ...