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Manager for Director International & Trusts Division Income Tax Rulings Directorate ...

., Manager for Director International & Trusts Division Income Tax Rulings Directorate ...

Subsection 73(3) states, in part, that "... the property was, before the transfer, used principally in the business of farming... ...

" Application of Section 143.1" of the Legal Opinion. Paragraph 143.1(1)(a) provides that where a NSO that is a registered Canadian amateur athletic association ("RCAAA") receives an amount for the benefit of an individual under an arrangement made under rules of an ISF that require amounts to be held, controlled and administered by the NSO in order to preserve the eligibility of the individual to compete in a sporting event sanctioned by the federation, an inter vivos trust (an Amateur Athlete Trust) is deemed to be created on the day that is the later of the day on which the first such amount is received by the NSO, and January 1, 1992, and to exist continuously thereafter until subsection 143.1(3) or (4) applies in respect of the trust. ...

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

It has approximately XXXXXXXXXX % of its workforce at customer sites in Quebec and less than XXXXXXXXXX% of its workforce in provinces other than Quebec and Ontario. ...

This provision includes as qualifying medical expenses, amounts expended "... for reasonable expenses relating to renovations or alterations to a dwelling of the patient who lacks normal physical development or has a severe and prolonged mobility impairment, to enable the patient to gain access to, or to be mobile or functional within, the dwelling"... ...

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

., details of the strata plan filed with the government, particulars regarding local municipal zoning bylaws at relevant times (past & present), accurate facts surrounding the history of the property including the expropriation, house demolition, green space requirements, etc.) to determine if the sale of the vacant lot could be treated as a disposition of part of the strata owners' principal residences. ...

The relevant part of the definition reads as follows: "testamentary trust" in a taxation year means a trust or estate that arose on and as a consequence of the death of an individual (including a trust referred to in subsection 248(9.1)), other than [...] ...