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" This principle was subsequently followed by the Supreme Court of Canada in Savage where the court interpreted the words "... benefits...in respect of, in the course of, or by virtue of an office or employment". ...

& Mrs. X) became resident in Canada. The shareholders of the corporation however do not alter. ...

29 July 1980 Income Tax Severed Letter July 29, 1980 Policy & Systems Non-Corporate Rulings Division M. ...

Section 70(1) of CBICA stipulates that the insurer must provide: "-- a statement of the conditions and affairs of the company on the 31st. day of December in each year, showing the assets and liabilities of the company-- together with such other information as the Minister may from time to time deem necessary. ...

Dictionary definitions also confirm this- see Funk & Wagnells- that which is obtained as an advantage;- a desired acquisition; Shorter Oxford- increase, of possessions, resources, or advantages, consequent on some action or event;- the action of acquiring; Concise Oxford- increase of possessions;- acquisition of wealth. ...

Robin Jackson Canadian Film & Videotape Certification Office Cultural Industries Directorate Department of Communications 16th Floor, Journal Tower South 365 Laurier Avenue, West Ottawa, Ontario K1A 0C8 Dear Robin: This is further to your letter of August 12, 1982 in connection with a proposal you have received from XXXX concerning XXXX While XXXX description concerning his proposals provide an illustrious description of his ideas and concepts, we are unable to draw definite conclusions as to whether or not any of the actual costs incurred will qualify as "computer software" within the meaning of paragraph (o) of class 12 of Schedule II to the Income Tax Regulations. ...

21 January 1985 Income Tax Severed Letter FOREIGN & SMALL BUSINESS SECTION D. ...

XXXX = 89%- see paragraph's 5 and 17 of Interpretation Bulletin IT- 171R) and therefore former section 118.91 would have denied a non- refundable tax credit otherwise allowable under section 118.1 except where the non-refundable tax credit otherwise permitted may reasonably be considered wholly applicable to the individual for the period or periods in the year throughout which he is resident in Canada, employed in Canada or carrying on business in Canada. ...

Paragraph 250(1)(d) of the Act provides: "For the purposes of this Act, a person shall... be deemed to have been resident in Canada throughout a taxation year if... he performed services, at any time in the year, in a country other than Canada under a prescribed international development assistance program of the Government of Canada and he was resident in Canada at any time in the 3 months' period preceding the day on which such services commenced", and Part XXXIV of the Income Tax Regulations provides: "... each international development assistance program of the Canadian International Development Agency that is financed with funds (other than loan assistance funds) provided under External Affairs Vote 30a, Appropriation Act No. 3, 1977-78, or another vote providing for such financing, is hereby prescribed as an international development assistance program of the Government of Canada". ...

Chief Finance, Insurance & Leasing Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch ...