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LAW: An "employee benefit plan" is defined in subsection 248(1) and the words which are relevant to the Plan described above are as follows: An arrangement under which contributions are made by an employer... to another person with whom the employer does not deal at arm's length (... the "custodian" of an employee benefit plan) and under which one or more payments are to be made to or for the benefit of employees or former employees of the employer or persons who do not deal at arm's length with any such employee or former employee. ...

Principal Issues:taxation of an out of court settlement pertaining to discrimination based on sex Position TAKEN:-settlement allocation unreasonable based on reported awards under the Ontario Human Rights Tribunals-amount for lost wages employment income-a reasonable amount for mental anguish & loss of dignity would be tax exempt-reimbursement of legal fees not taxable Reasons FOR POSITION TAKEN: the lost wages are not for loss of employment since she resigned voluntarily February 9, 1995 TORONTO CENTRE TAX SERVICES Rulings Directorate Source Deductions Division A. ...

Bonner concluded that "... Mere repetition does not necessarily change the character of the activity...the level of activity shown in evidence is not indicative of the existence of a money lending business. ...

M.N.R. (85 DTC 272) both contain comments regarding what "... can reasonably be regarded as contributing to the use and enjoyment of the housing unit as a principal residence... ...

If you dispose of the units after you have established Canadian residency, you will be taxable on 75 % of your capital gain on the disposition, and in general, the capital gain would be the difference between the selling price of the properties and their fair market value at the time you immigrated to Canada. ...

In this regard, as the determination of fair market value is a question of fact, we refer to Question # 32 of the Revenue Canada Round Table held at the 1989 annual conference of the Canadian Tax Foundation concerning the valuation of government rights where we stated: "The Department has not established valuation guidelines...for... property created by licensing or quota arrangements by various levels of government. ...

Cloutier 7-950601 XXXXXXXXXX Revised Resource Allowance in nil years We are writing in response to your March 2, 1995 request for our opinion on whether producers in the Oil & Gas and Mining Industries may increase resource allowance claims in taxation years with nil taxable income. ...

Alternativement, l'alinéa 12(1)b) de la Loi pourrait être invoqué; tel que précisé au paragraphe 5 du bulletin d'interprétation IT-170R: " le Ministère est d'avis que, aux fins de l'impôt, il doit être tenu compte du prix de vente d'un bien vendu lorsque le vendeur a le droit absolu, mais pas nécessairement immédiat, d'être payé. ...

" Dans le Robert, dictionnaire alphabétique et analogique de la langue française, le mot "prestation" signifie: " législ. soc. ...

Yours truly, for Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...