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Principal Issues: Does Bco, a Japanese company, dispose of its assets, including its shares of Cco (a "taxable Canadian corporation" in the oil & gas business in Canada), if Bco merges with Aco (another Japanese company that is Bco's parent) and the corporate law in Japan is of a "continuation type", as described in The Queen v. ...

In our view, training benefits (including tuition, allowances & books) provided to individuals which are funded under the EI Act are taxable under paragraph 56(1)(r) of the Income Tax Act (the "Act"). ...

Principal Issues: Whether travel expenses & expenses of new accommodations to facilitate obtaining medical care/ instruction for a dependant who has received a cochlear implant qualify for the medical expense tax credit Position: Expenses are not qualifying medical expenses. ...

Income Tax Convention (the " Convention"). In general terms, Article XVII of the Convention provides that pension payments arising in the U.K. that are paid to a resident of Canada will only be taxable by Canada. ...

The fact that a full-time employee does not deal at arm's length with the proprietor would not disqualify the plan, provided that such employee is receiving coverage as an employee and not because of the relationship with the proprietor / employer. ...

Article 4(1) of the Convention states: For the purposes of this Convention, the term "resident" of a Contracting State means any person that, under the laws of that State, is liable to tax therein by reason of that person's domicile, residence, citizenship, place of management, place of incorporation or any other criterion of a similar nature, but in the case of an estate or trust, only to the extent that income derived by the estate or trust is liable to tax in that State, either in its hands or in the hands of its beneficiaries. [...] ...

You have asked us to confirm that: The capital cost to the transferee is $2,750 ($2,400 + ($3,100- $2400)/2). ...

Other Comments Pursuant to paragraph (g.1) of the definition of "Canadian exploration expense" ("CEE") in subsection 66.1(6) of the Income Tax Act (the "Act"), expenses incurred by a taxpayer that qualify for inclusion in "Canadian renewable and conservation expense" (" CRCE", also as defined in the above subsection of the Act) will be included in the taxpayer's CEE. ...

Pursuant to paragraph (g.1) of the definition of "Canadian exploration expense" ("CEE") in subsection 66.1(6) of the Act, expenses incurred by a taxpayer that qualify for inclusion in "Canadian renewable and conservation expense" (" CRCE", as defined in the above subsection of the Act) will also be included in the taxpayer's CEE. ...

When fewer items are bought during the period described in the definition of "superficial loss" than were sold during that period, the Canada Revenue Agency administratively accepts that the amount of the "superficial loss" may be determined by using the following algebraic formula: SL = (Least of S, P and B)/S x L where SL is the superficial loss, S is the number of items disposed at that time, P is the number of items acquired in the 61-day period, B is the number of items left at the end of period, and L is the loss on the disposition as otherwise determined. ...