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The test as to whether separate businesses exist is found in Scales v George Thompson & Company Limited (1927), 13 TC 83. ...

As stated in paragraph 7 of Interpretation Bulletin IT-433 entitled Farming-Use of Cash Method, "... in certain factual circumstances it is considered that farming includes raising fish... ...

Technically, it is our view that an election would not be available to the lessee under subsection 13(7.4) since the amount was not “... received... in respect of... a depreciable property acquired by him...”. ...

7 November 1991 Income Tax Severed Letter- Goods and Services Tax Rebate- Employees and Partners Unedited CRA Tags 6(8), 12(1)(x), 13(7.1)(d), 20(1)(hh), 70(1), 70(2), 253 Subject: Goods and Services Tax Rebate Employees & Partners This is in reply to your memorandum dated July 9, 1991 wherein you requested our opinion concerning the application of several amendments to the Income Tax Act (the "Act") as part of Bill C-62. ...

"... In substance, the term is the space of time during which the debtor cannot be required to make, and the creditor to receive, the payment of the debt. ...

The DNR has made two public comments on the issue: (a) 1980 Conference Report: Q.23 “... shares issued on the incorporation of a wholly-owned subsidiary would not as a rule be in the ordinary course of business.” ...

Paragraph 11 of IT-496, suggests that enabling documents may provide that all of the “... assets and accumulated income are to be transferred to an organization with similar objects that qualifies for exemption pursuant to paragraphs 149(1)(f) or (l) of the Act”. ...

As stated in paragraph 1 of IT-85R2, in order to qualify as a Health & Welfare Trust, the benefit programs funded through the trust must be restricted to one or more of the following plans: a) a private health services plan, b) a group sickness or accident insurance plan, or c) a group term life insurance police. ...

Comments With regard to your first question, subsection 85(6) of the Act requires that an election made under subsection 85(1) of the Act "... be made on or before the earliest of the days on or before which any taxpayer making the election is required to file a return of income pursuant to section 150 of the Act for the taxation year in which the transaction to which the election relates occurred. ...

., using an appropriate per-kilometre rate applied to all business kilometres driven by the employee), that is not otherwise “deemed” an unreasonable allowance [subparagraphs 6(1)(b)(x) & (xi)], then deductions at source from the allowance would not be required. ...