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14 June 1989 Income Tax Severed Letter 89M06085 F- Northern Residents Deductions Unedited CRA Tags 110.7   June 14, 1989 CGA ASSOCIATION ROUND TABLE NORTHERN RESIDENTS DEDUCTIONS QUESTION 8 The condition of "lived in this area for a period of at least six continuous months" seems to be very restrictive to individuals who work at remote sites for more than six months and who return to their regular residence on timed interval weekends, within this period, thus breaking the continuous residency test. ...

Khosla, Chief of Audit Rulings Directorate   J.D. Brooks 957-2103 Attention:  R. ...

" For your information we are enclosing photocopies of the memorandum to and from Legal Services, Corporate Rulings Division, Toronto District Office and Coopers & Lybrand. ...

PENSION & PROFIT SHARING PLANS SECTION REGISTRATIONS DIVISION Mr. ...

Delorey 995-0051 Estate & Trust Income Canada-U. K. Tax Convention This is in reply to your memorandum of December 17, 1981 concerning a U.K. resident beneficiary of a Canadian trust or estate. ...

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

15 March 1983 Income Tax Severed Letter March 15, 1993 Registration Division Pension & Profit Sharing Plans Section Mr. ...

17 November 1982 Income Tax Severed Letter DECISION SUMMARY Services, Public Utilities & Exempt Corporations Section J.F. ...

You have indicated that you received a CHIP grant of $ XXXX in connection with your insulating your house in 1980 with urea formaldehyde foam insulation, and paid income tax on that grant. ...

You have stated that "special executive compensation benefits" are expenses which would have been otherwise deductible under paragraph 110(1)(c) of the Act. 2) To the extent that they are reasonable, company contributions, in respect of its own employees, to a private health services plan are deductible when paid. 3) An employee benefit plan as defined in section 248 of the Act does not include a private health services plan. 4) A health and welfare trust is taxed as described in items 8 & 9 of IT-85R. 5) Because of the variety of plans and rates existing in the insurance industry, it is our view that the requirement that premiums should be computed using actuarial or similar studies would not be satisfied if payments to the health and welfare trust were based on market rates quoted by insurance companies for plans with substantially similar coverage. 6) Although there is no limit on the number or types of employees that may be covered by a plan we would generally consider that in the case of a "one man company" coverage would be received by virtue of the individual's shareholdings rather than by virtue of his employment. 7) A private health services plan does not include a simple unconditional contract to defray employee's costs. ...