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Yours truly, for Director Financial Industries Division Rulings Directorate Policy & Legislation Branch ...

The reason being that subsection 12(10.2) & (10.3) specifically dealt with NISA. ...

Principal Issues: whether the XXXXXXXXXX offers specialized programs for learning disabled students & whether the basic fees paid for 2 students is deductible as a medical expense Position: no Reasons: while school offers highly specialized programs for the learning disabled, the educational and pyschological assessments submitted in respect of the children do not establish that the children's learning disabilities are so severe as to require services not available in the public school system-see E9603255, E942381A, E9029335 XXXXXXXXXX 960902 May 28, 1996 Dear XXXXXXXXXX: Re: Medical Expense Claim We are replying to your letter of February 24, 1996 in which you ask whether you are entitled to claim the tuition fees paid to the XXXXXXXXXX on behalf of XXXXXXXXXX as a medical expense. ...

Yours truly, Chief Partnerships Section Resources, Partnerships & Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

Your interpretation of the application of paragraph 13(21.1)(b) is that it results in deemed proceeds calculated as follows: Paragraph 13(21.1)(b) deems the proceeds of disposition to be: The aggregate of: (i) the proceeds otherwise determined Nil plus (ii) 1/4 of the greater of: (A) UCC of building $60,000 or (B) Excess of FMV over (i) amount ($2,000-nil) = $2,000 The (ii) amount is, therefore, $15,000 (1/4 of $60,000) which when added to the (i) amount of nil results in deemed proceeds of $15,000. ...

Yours truly, for Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch c.c.Barbara Larocque Policy & Technical Services Section Trust Accounts Division Room 7000, Cumberland Place ...

Position Adoptée: Oui, si employé est bénéficiaire Raisons POUR POSITION ADOPTÉE: # 9 IT-430R2 XXXXXXXXXX 5-961645 G. ...

Position: Maybe depending on whether it is a property at all & has any value in the circumstances. ...

As a result of the June 13, 1996 Tribunal Decision by the Canadian Human Rights Commission in the case of Stanley Moore & Dale Akerstrom, we have reviewed our position with respect to the definition of a "private health services plan," as found in subsection 248(1) of the Income Tax Act. ...

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