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The intention of the declaratory order is to circumvent the new child support rules; however, the OCA did recognize that it “has no jurisdiction to decide appeals provided for in the Income Tax Act ”. ...

However, the amount entitled to in the year of acquisition of the property should be restricted to the amount received, for consistency under IT 53R and 174R and based on document # 973080. ...

Spice for Director Financial Industries Division Income Tax Rulings & Interpretations Directorate- 3- ...

It seems that the “XXXXXXXXXX ” would be subject to the comments above on paragraph 18 of IT-529, since the documentation indicates that the employees would pay for the medical coverage, on a pre-tax basis. ...

After the sale XXXXXXXXXX owned approximately XXXXXXXXX % of the outstanding common shares of XXXXXXXXXX. ...

However, we are prepared to provide the following comments which are of a general nature, As you may know, child support payments made pursuant to a written agreement or court order that has a " commencement day” as defined in subsection 56.1(4) of the Act, are subject to the new rules and, as such, are not deductible by the payer and are not required to be included in the income of the recipient. ...

ABC Corp wishes to change its present arrangements so that: a) a death benefit is paid, in recognition of the employee's service, equal to the present insurance benefit but not to exceed $10,000; b) the amount of group term life insurance would be equal to the present amount minus the amount of the death benefit; and c) the group term life insurance benefit would be funded through the existing employee health & welfare trust. 5. ...

Par ailleurs, conformément au paragraphe 122.3(2) de la Loi, un «employeur déterminé» est soit: a) une personne résidant au Canada; b) une société de personnes dont la valeur totale des participations appartenant à des personnes résidant au Canada ou à des sociétés contrôlées par des personnes résidant au Canada est supérieure à 10 % de la juste valeur marchande totale de toutes les participations dans la société de personnes; c) une société qui est une société étrangère affiliée d'une personne résidant au Canada. ...

Benefit coverage under a plan or policy administered by a HWT As discussed in paragraph 1.1 of Income Tax Folio S2-F1-C1, Health and Welfare Trusts (“Folio S2-F1-C1 ”), a HWT is “a trust arrangement established by an employer for the purpose of providing health and welfare benefits to its employees.” ...

As discussed in ¶2.3 of Income Tax Folio S2-F1-C2, Retiring Allowances: “A retiring allowance is defined in subsection 248(1) of the Act as an amount received by an individual: on or after retirement of the individual from employment in recognition of the individual’s long service; or in respect of loss of employment of the individual, whether or not received as, on account of or in lieu of payment of, damages or pursuant to an order or judgement of a competent tribunal. ” Since the Order Amount is being paid to each Employee who was in the bargaining unit when the unfair labour practice was committed, it is unlikely that the Order Amount would be a retiring allowance. ...