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Our Comments 1) & 2) In order for payments that are received by an individual to provide foster care to be exempt from income under paragraph 81(1)(h) of the Income Tax Act (the "Act") all of the following conditions must be met: (i) The payments must be ordinarily made on the basis of a means, needs, or income test. ...

Your enquiry stemmed from your review of an interpretation we issued on March 6, 2001 (document # 2000-0049105) where we concluded that a corporation carried on a "specified investment business" since it did not employ more than 5 full-time employees for the portion of the year after two rental properties were surrendered at the same time due to foreclosure. ...

Reasons: (1) Subsection 13(1), paragraph 28(1)(d) and paragraph 40(1)(a). (2) Paragraph 12(1)(b) & 28(1)(d) XXXXXXXXXX 2001-011551 Randy Hewlett, B.Comm. ...

Prepared by: Tim Kuss International section Date: November 2001 File # 2001-011094 ...

Principal Issues: Where an individual disposes of shares to a personal Holdco & Holdco immediately thereafter disposes of same shares to individual's self-directed RRSP will 1) 40(2)(g)(i) apply? ...

The Supreme Court of Canada found in Savage, 83 DTC 5409 and Nowegijick, 83 DTC 5041 that the words "in respect of" are "... of the widest possible scope". ...

We would also note that the allocation of an employee and the totalling up of bits and pieces so as to arrive at more than 5 full-time employees is generally not considered by the courts as being consistent with the intention of the provision (see Federal Court of Appeal and Tax Court of Canada decisions in Lerric Investments Corp. and Federal Court-Trial Division decision in Hughes & Co. ...

ManagementCo was incorporated a number of years ago and solely provides administrative support services to the Law Partnership, and bills the Law Partnership on a cost + 15% basis. ...

Murphy Manager Trusts Section International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

April 8, 2002 XXXXXXXXXX Jane Stalker Tel: (613) 946-8764 Fax: (613) 941-5932 ID# 2002-112588 HBW # 4125-4/49 HBW #4125-7/18 Dear XXXXXXXXXX: Re: Pensions received from Germany We are responding to your facsimile received March 25, 2002, in follow up to our telephone discussion, in respect of the tax treatment of certain pensions received by Canadian residents from Germany. ...