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Yours truly, Randy Hewlett Director International Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Moore for Director Partnerships & Corporate Financing Section International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Your view is that upon the declaration of the dividend by NRCo a "debtor – creditor" relationship arises between NRCo and the shareholder and as a result, in Scenario 1, the amount paid by NRCo to the shareholder after the Immigration Day should not be considered a dividend, but should rather be considered a payment to discharge the debt claim arising as a result of the declaration of the dividend. ...

For additional information on BIL, please see Interpretation bulletin IT-484R2, ARCHIVED – Business Investment Losses, on the CRA's web site. ...

In that case, Judge Estey, J. concluded that "... one is ordinarily resident in the place where, in the settled routine of his life he regularly, normally or customarily lives". ...

March 5, 2010 James Atkinson CGA XXXXXXXXXX (519) 457-4832 2010-035584 Attention: XXXXXXXXXX Re: Canada-PEI Business Development Programs: Self-Assessment, Financials, Planning & Skills This is in response to your email dated January 28, 2010 concerning the above named programs. ...

Burke, 76 DTC 6075 (FCTD), the judge noted that “… the expression ‘superannuation fund or plan’ is broad enough to include any fund or plan for providing payments to persons who have by reason of age or disability ceased to be employed either entirely or in a particular position and whether or not the fund or the payments are provided at the expense of the employer or former employer.” ...

The Definition reads as follows: " "eligible apprentice" means an individual who is employed in Canada in a trade prescribed in respect of a province or in respect of Canada, during the first twenty-four months of the individual's apprenticeship contract registered with he province or Canada, as the case maybe, under an apprenticeship program designed to certify or license individuals in the trade;" Quebec- the CCQ In Quebec, apprentices in the construction trades are required to be registered as apprentices with the CCQ. ...

La prime annuelle est de 10 000$ et le capital assuré est de 500 000 $. ...

OUR COMMENTS Interaction of subsection 80.01(3), subsection 80(1) "Forgiven amount" and paragraph 80(2)(k) Subsection 80(1) defines the term "forgiven amount", in part, as follows: " 'forgiven amount' at any time in respect of a commercial obligation issued by a debtor is the amount determined by the formula A- B Where A is the lesser of the amount for which the obligation was issued and the principal amount of the obligation, B is the total of, a) The amount, if any, paid at that time in satisfaction of the principal amount of the obligation,.... ...