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., (B) all amounts each of which was included in computing the individual's income for the year and is a single payment out of or under a deferred profit sharing plan, a superannuation or pension fund or plan or a foreign retirement arrangement (I) as a consequence of the death, withdrawal from the fund, plan or arrangement or termination of employment of a person, (...)" ...

The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

In 1980, A and B entered into a Shareholder Agreement (the "Agreement") which provided, inter alia, that Opco would acquire a term life insurance policy (no cash surrender value) in the amount of $) million on the life of each shareholder. ...

This is consistent with Justice Pinard's comments at page 6396 in the Federal Court-Trial Division case of Gaynor v The Queen [[1988] 2 C.T.C. 163] (88 DTC 6394), where he states: "... when the Income Tax Act, a Canadian statue, requires that a gain, a loss, a cost or a price be established or considered, that must be done in Canadian dollars at the relevant time, i.e. at the average exchange rate prevailing at the time such gain or loss occurs, and such cost or price is encountered. ...

As well, the "attributable to " concept thereunder will also have a significant impact. ...

Scenarios 2 & 3 With respect to the period throughout which the individual is not resident in Canada, section 115 is applicable but does not provide for the inclusion in income of any interest accrued during this period. ...

The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

Former IT-436 contains comments in paragraphs 9 & 10 which, although not included in IT-436R due to the introduction of new 5 year time limit restrictions, are still considered relevant in some situations. ...

Yours truly, Chief Leasing & Financing Financial Industries Division Rulings Directorate ...

Yours truly, Section Chief Leasing & Financing Section Financial Industries Division Rulings Directorate Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...