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Le bulletin d’interprétation IT-430R3 et les Nouvelles techniques # 10 traitent des conséquences fiscales pour une société privée lorsqu’une police d’assurance-vie est utilisée pour garantir une dette. ...

Principal Issues: health spending accounts- expenses incurred prior to participation in the plan Position: a plan which reimburses such expenses is not a plan of insurance & thus not a PHSP Reasons: can be distinguished from a plan which does provide insurance but permits the carry-forward of expenses in excess of annual ceiling limits 973032 XXXXXXXXXX A. ...

Principal Issues: meaning of "at demand of " in 131(8)(c)(i); whether corporation precluded from being mutual fund corporation where the first valuation date and payment of the redemption price is delayed for 180 days after the first mutual fund share is issued? ...

Reasons FOR POSITION TAKEN: Owing to the ambiguity of the information provided (unable to contact as no telephone # included with the request) our response was limited to general comments. ...

Our Comments We have reviewed the above situation and concluded that it does not meet any of the guidelines in Revenue Canada’s publication “ Indian Act Exemption for Employment Income”(copy attached). ...

The Department's position on the tax treatment of expenditures that are of a capital nature versus those that are of a current nature is generally covered in Interpretation Bulletin IT-128R, Capital cost allowance — Depreciable property. ...

Further, the phrase “one full-time attendant ” limits amounts claimed as a medical expense to an amount paid in respect of an individual and can be satisfied in whole or in our part by one or more persons employed for that purpose but, as noted in paragraph 24 of IT-519R2, only so long as there is only one attendant for any given period of time. ...

As this question pertains to the completion of the T3, we have forwarded it to Joe Hartwick (telephone # 613-957-9352) of the Business Returns Processing Division for a direct response. ...

You are requesting clarification on comments made in our letter to you of May 26, 1998, (our reference # 980574) in regard to the fact that bonuses paid should relate to the expertise, skills and services provided to the corporation. ...

The comment in the letter alluding that Revenue Canada requires “... an appraisal from a recognized appraiser along with three comparable listings within the same area indicating that the value of the property...”, when writing off a mortgage is not correct. ...