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(In the present case a penalty will apply if an employee retires before the employee's total years of service plus age = 85) If an employer's plan allows an employee to count years of service with a former employer in order to reduce this penalty, we take the position that the years of service with the former employer are being recognized in computing the retiree's pension benefits. ...

Yours truly, Manager Financial Institutions Section Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch... ...

The criteria in subparagraph (a)(vii) is met if the property was used by the individual "... principally in the course of carrying on the business of farming in Canada A) in the year the property was disposed of by the individual, or B) in at least 5 years during which the property was owned by the individual... ...

Agri-Land Sales & Leasing 900- 1801 Hamilton Street Regina, Saskatchewan 963606 S4P 4L5 A.M. ...

Reasons: Brokerage fees are a cost of acquisition & are added to "cost amount" of securities purchased. ...

Jim Ivey, Section Chief Policy & Technical Services Section Trust Accounts Division?? ...

De façon générale, ces nouvelles exigences prévoient que certains contribuables résidant au Canada et certaines sociétés de personnes seront tenus de produire une déclaration de renseignements relativement à leurs biens étrangers, si le coût indiqué global de ces biens dépasse 100 000 $. ...

Principal Issues: whether payments into an estranged spouse's RRSP are deductible as alimony or maintenance Position: no but they may be deductible as a contribution to a spousal RRSP, subject to the contributor's RRSP room & the monthly tax on any "cumulative excess amount" Reasons: while 60.1(1) may deem the contribution to have been paid for the benefit of the spouse, a payment that is intended to equalize family assets is not on account of maintenance A. ...

In the definition "small business corporation" contained in subsection 248(1) of the Income Tax Act (the "Act") there is a requirement that "... all or substantially all of the fair market value of the assets... are used principally in an active business... ...

Oulton Section Chief Business, Property & Personal Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...