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In summary, if the first series qualified for distribution to the public, any of the following scenarios would enable the trust to qualify: 150 unitholders of 100 units of the first series; 150 unitholders of 25 units of the second series; (150- N) unitholders of 100 units of the first series + N unitholders of 100 units of the second series. ...

You posed this question: With the introduction of section 80.4(1.1)(b), to the extent evidence clearly exists that " it is reasonable to conclude that...the debt would not have been incurred" were it not for the employee's relocation, notwithstanding the introduction of section 6(23), would the taxable benefit under such arrangements be computed in accordance with the provisions of section 80.4? ...

More specifically, you have requested our comments regarding question # 2 on form T2200 regarding whether you normally require the employees to work away from your place of business, or in different places. ...

To the extent that it relates to a past transaction you should contact the appropriate Tax Services Office of the Canada Customs & Revenue Agency (the "CCRA"). ...

Our Comments: The taxation of the lump sum cash payments and the mobility payments available under the FRA program have been discussed in an earlier letter to Human Resources Development Canada (“HRDC”) (file # 5-982005). ...

L'allocation maximum est de XXXXXXXXXX $ par mois. Cette allocation est fournie en tout ou en partie par les parents naturels de l'enfant. ...

Comments were also provided based on the assumption that XXXXXXXXXX % of the store was on reserve and employees worked throughout it. ...

For a discussion of “private health services plan,” we refer you to Interpretation Bulletins IT-529 (paragraphs 14 through 18) and IT-339, “Meaning of ‘Private Health Services Plan.’ ” In your letter, you stated that the client’s flex plan does not represent the trading of vacation entitlement. ...

La couverture de la police est d'environ XXXXXXXXXX $. Le XXXXXXXXXX, OPCO continuait de posséder la police d'assurance-vie afin de financer le rachat d'une partie des actions privilégiées du capital-actions de GESTCOB possédées par GESTCOA après le décès de M. ...

We also noted the fact that your brochure indicates that employees would be entitled for reimbursement of "any medical expenses that qualifies under the Income Tax Act ". ...