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Subsection 62(1) of the Income Tax Act (the "Act") allows a taxpayer to deduct moving expenses incurred in respect of an eligible relocation which is further defined in subsection 248(1) of the Act as, among other things, a relocation to enable the taxpayer to be employed at a location in Canada, referred to as " the new work location". ...

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Convention Position: word distributed also applies to amounts credited in this case Reasons: as 214(3)(f) deems amounts to be paid or credited & does not differentiate between the two amounts, therefore an amount deemed to be paid or credited would be subject to p.2 of Article XXII XXXXXXXXXX L. ...

Diguer CGA Attention: XXXXXXXXXX September 18, 2000 Dear Madam: Re: Reimbursement received by a corporation on issuing shares of its authorized capital This is in reply to your letter dated May 29, 2000 in which you request the Canada Customs & Revenue Agency's (the "Agency") views on the tax consequences to a Canadian corporation ("Parentco") of a reimbursement received from a foreign subsidiary ("Foreignco") where shares of the capital stock of Parentco are issued by it under the terms of Foreignco's employee stock option plan. ...

Position: i) No ii) & iii) We cannot provide an opinion as we are unable to determine all the relevant facts and circumstances of the particular situation. ...

XXXXXXXXXX 2000-005547 Yves Leclerc Attention: XXXXXXXXXX January 4, 2001 Dear Sir: Re: Interest deduction on funds borrowed to redeem preferred shares This is in reply to your letter dated November 3, 2000 in which you seek clarification concerning the Canada Customs & Revenue Agency's (the "Agency") policies on deducting interest under paragraph 20(1)(c) when money is borrowed in order to pay dividends or redeem shares. ...

Agency's Position The time limitation set out in subsection 152(4.3) states: "... and the end of the day that is one year after the day on which all rights of objection and appeal expire or are determined in respect of the particular year,... ...

Clause 6801(a)(iv)(A) of the Regulations includes the following condition: "..., and provides that the amount that may reasonably be considered to be the income of the trust for a taxation year that has been earned by it for the benefit of the employee shall be paid in the year to the employee". ...

Position: no benefit provided that upkeep is paid out of capital and the property would have been the principal residence of the life tenant if the life tenant had owned the property Reasons: 105(2) only applies if the upkeep is paid out of the income of the trust and as stated at the 1988 & 1989 CTF conferences, the ccra will generally not assess a 105[1] benefit if the property would qualify as the life tenant's principal residence if the life tenant had owned it XXXXXXXXXX 2000-004675 Annemarie Humenuk February 27, 2001 Dear XXXXXXXXXX: Re: XXXXXXXXXX This is in reply to your letter of May 16, 2000, addressed to the XXXXXXXXXX Tax Services Office, in which you ask us to confirm that neither subsection 105(1) nor (2) of the Income Tax Act will apply to the spousal beneficiary of the above-noted estate occupying a residence owned by the estate. ...

Yours truly, Roberta Albert, CA for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...