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Accordingly, you have asked whether, in such a situation, a WLRP could be provided through the establishment of a health & welfare trust. ...

.): (...) it is my opinion that a purchaser has acquired assets of a class in Schedule B when title has passed, assuming that the assets exist at that time, or when the purchaser has all the incidents of title, such as possession, use and risk, although legal title may remain with the vendor as security for the purchase price as is the commercial practice under conditional sales agreements. ...

We have informed the Department of Finance ("Finance") of this circularity problem, however, should you wish to pursue this matter we would suggest that you write to Finance at the following address: Tax Policy & Legislation Branch Department of Finance 140 O'Connor Street L'Esplanade Laurier 17th Floor, East Tower Ottawa, Ontario K1A 0G5 In general subsection 110.6(8) of the Act is an anti-avoidance rule enacted to prevent the conversion of dividend income into exempt capital gains. ...

Principal Issues: self-administered phsps & the rules relating to c/f, eligible expenses, etc. ...

Principal Issues: can a disability plan to which the employer has contributed be converted to an employee pay all plan as originally intended-issue of retroactive changes and what constitutes a new plan as opposed to a continuation of an existing plan (where the liability for premiums has been shifted from employer to employees) Position:-cannot retroactively change the plan & it is a question of fact as to whether a plan amendment creates a new plan-the existing plan will be a plan which is subject to 6(1)(f) even if the plan documentation indicates otherwise because the employer did make contributions to it even if that was not the intent Reasons: question of fact to be determined by TSO or a ruling A. ...

Raisons POUR POSITIONS ADOPTÉES: i)Dossier # 920366. ii)Question de fait. 5-953023 XXXXXXXXXX Philip Diguer A l'attention de XXXXXXXXXX Le 29 janvier 1996 Mesdames, Messieurs Objet: Avantages conférés aux employés La présente est en réponse à votre lettre du 13 novembre 1995 par laquelle vous nous demandez notre opinion concernant l'objet mentionné en titre. ...

Yours truly, Chief Financial Institutions Section Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

We have reviewed the list of reasons for the payment of Subsidies listed on the blank "Subsidy Agreement- Terms & Conditions" included with your letter and note that payments for many of the items listed would be excluded from reporting on a T5007 because of the exclusions in subsection 233(2) of the Regulations listed above. ...

". Paragraph 126(6)(a) states that "the government of a country other than Canada includes the government of a state, province or other political subdivision of that country;... ...

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. ...