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Although subsection 102(2) provides that "... a reference to a person or a taxpayer who is a member of a particular partnership shall include a reference to another partnership that is a member of the particular partnership", it is a limited deeming provision and does not deem the partnership that continues the business to be either "one" person or to carry on "alone" the business, which are prerequisites for the application of subsection 98(5). ...

(see Koop, Klassen & Rushton (Youth for Christ Employee) XXXXXXXXXX 2000-006144 C. ...

Principal Issues: "Benefit" from an RRSP after Annuitant's Death Position: Amount received is a benefit unless previously included in annuitant's income pursuant to 146(8) & (8.8) Reasons: Definition of "benefit" in 146(1) XXXXXXXXXX 990453 M. ...

Proposed subsection 6(23) of the Act provides that "... an amount paid or the value of assistance provided... in respect of, the financing of... a residence is... a benefit received by the individual because of the office or employment. ...

Principal Issues: Correction of prior opinion # 990160 stating that subsection 6(6) allowances are not subject to Employment Insurance premiums. ...

Reasons: See file # 9624285, 922362, 970474. Also see paragraph 13 of IT-499R. ...

Spice for Director Financial Industries Division Income Tax Rulings & Interpretations Directorate ...

For purposes of the definition of "qualified farm property, " "child" has the meaning assigned by subsection 70(10) of the Act. ...

Yours truly, for Director Resources, Partnerships & Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch cc: Mr. ...

Pursuant to the Yukon Act, "eligible taxpayer" for the YMETC for a taxation year means: •.. a corporation that maintains a permanent establishment in the Yukon at any time in the year, other than a corporation (i) that is exempt from tax payable under this Act by reason of section 7, or (ii) that is controlled by one or more persons who are exempt from tax payable under this Act by reason of section 7... ...