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Principal Issues: taxation of the withdrawal of RRSP funds by a trustee for an insolvant person Position TAKEN: withdrawal of RRSP funds is included in the insolvant person's income for the year Reasons FOR POSITION TAKEN: an insolvant person is not a bankrupt person so 128 doesn't apply & if the RRSP vests with the trustee, 146(2)(c) will require the insolvant person to include the RRSP funds in income because of the divesting to the trustee May 16, 1994 HEAD OFFICE WINNIPEG DISTRICT OFFICE Rulings Directorate A. ...

The projects identified included the XXXXXXXXXX Our Comments As you may be aware following the decision in the Williams case and as a result of a letter issued by the Department on December 29, 1992, which was followed up with considerable input from the Indian community, the Department has developed " INDIAN ACT EXEMPTION FOR EMPLOYMENT INCOME DETAILED GUIDELINES". ...

In this regard, we have attached a copy of a letter from the Internal Revenue Service regarding the "merger of the Railroad Retirement Act and the Social Security Act " as well as a letter from the U.S. ...

Cinq individus qui ne sont pas liés entre eux sont les commanditaires et chacun fait une mise de fonds initiale de 25 000 $ dans la société. ...

The issue arises as a consequence of comments we set out in a letter dated April 28, 1993 (file # 923828) which you enclosed. ...

Principal Issues: whether there are timing restrictions involved in a home relocation loan as defined in 248(1) Position TAKEN: effectively yes Reasons FOR POSITION TAKEN: 3 possible timing delays noted: a delay between granting of loan and purchase of home suggests that loan was not used for the purpose of acquiring the home, a delay between the relocation to new city and purchase of home suggests that employee lived in another place during the delay- if it can be said that the employee ordinarily resided at that other place then the loan to purchase any other home will not be a home relocation loan because the house purchased is not the new residence & finally, a significant delay between the commencement of work at the new workplace and the relocation to that place might suggest that the eventual relocation is not occasioned by the change in workplaces (although we have acknowledged that we would accept the causal relationship if the relocation occures within 1 year of the change in workplaces) June 21, 1994 HEAD OFFICE WINNIPEG TAXATION CENTRE Rulings Directorate T1 Client Services A. ...

From the sample letter from the bank, used to substantiate the reimbursements related to the bridge financing, the monthly payments made to the bank on October 22 and November 1, 1993 were as follows: Oct 22: interest only on the collateral loan $ XXXXXXXXXX Nov 1: principal, interest and taxes on first mortgage XXXXXXXXXX Nov 1: premium in respect of life insurance XXXXXXXXXX $XXXXXXXXXX The District Office has asked whether the reimbursement of $XXXXXXXXXX (for the interest on the collateral loan and the payments in respect of the first mortgage) is deductible by the employee as a moving expense or alternatively whether it can be considered a non-taxable reimbursement described in paragraphs 35-38 of Interpretation Bulletin IT-470R "Employees' Fringe Benefits". ...

Position TAKEN: no Reasons FOR POSITION TAKEN:-Paragraph 18(1)(a)-files 932751 & 940016 September 1, 1994 XXXXXXXXXX District Office Head Office Business Enquiries Rulings Directorate B. ...

Pierre Paquette of Head Office Source Deductions Division, CPP & UI Programs (613-952-5422) for comment. ...

October 11, 1994 Assessment of Returns Directorate Head Office T1 Programs Division Rulings Directorate T1 Assessment & Reassessment J.A. ...