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It is also a question of fact as to whether the assistance qualifies under paragraph (a)(i) of the definition of "qualifying educational program" in subsection 118.6(1) as "an amount received [...] as a scholarship, fellowship or bursary or a prize for achievement in a field of endeavour ordinarily carried on by the student" so as not to be excluded under paragraph (a) of that definition. ...

Une somme de XXXXXXXXXX $ doit ainsi être versée dans un fonds de règlement pour servir au paiement des réclamations des employé(e)s admissibles ou leurs ayants droit. ...

For Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

If the "Total Shareholder Return" exceeds the Benchmark and is in the top quartile at the end of the third year of the Plan, then all Share awards will vest at that time and an additional XXXXXXXXXX % of the original number of Shares awarded will be added; b. ...

., e.g. a church, school, college, hospital, asylum, reformatory, mission or the like; [...] ...

" In Bethlehem Copper Corporation Ltd (74 DTC 6520), the Supreme Court stated that "... there is a mine within the meaning of s. 83(5) if there is a body of ore together with the workings, equipment and machinery capable of producing it. ...

The meaning of disposition of property has been interpreted broadly in Olympia & York 80 DTC 6185 (FCA) and Robert Bédard 85 DTC 643 (TCC) to include transactions or events that are not sales. ...

Comments We maintain the view expressed in our document dated September 13, 2000 (# 2000-0042885) that a derivative agreement such as a swap or forward contract is a contractual arrangement separate from any associated asset or liability for which it may be designed to hedge. ...

The taxpayer referred to two documents (#9032185 and # 2002-0152203) issued by the Canada Customs and Revenue Agency (the "CCRA") to support their arguments. ...

Reasons: See File # 980159 and 983032. "Travel expenses" includes air, train and bus fares, meals, hotel and motel accommodations, camping fees, incidentals such as taxis, road and ferry tolls, and automobile expenses directly related to the trip such as the cost of fuel, general maintenance (ex. oil, grease and servicing charges), repairs, licenses, and insurance as long as the costs are reasonable, are not on account of capital, and can reasonably be attributed to the trip. ...