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Her Majesty the Queen (FCA) 2002 DTC 7442 XXXXXXXXXX 2007-023099 Sylvie Labarre, CA November 13, 2007 Dear Sir: Re: Overseas employment tax credit This is in reply to your electronic message of March 25, 2007 in which you requested our views with respect to your entitlement to the overseas employment tax credit (OETC). ... Her Majesty the Queen (2002 DTC 7442). In that case, the individual had only one specified employer but performed his duties of employment outside Canada in connection with a number of contracts, rather than a single contract and the Federal Court of Appeal stated that the conditions in section 122.3 of the Act could be met even if the work done in the qualifying period related to more than one contract. ... During a period of absence from a work location outside Canada, an employee may take vacation time, consult with the specified employer in Canada or perform duties of employment in Canada and still remain eligible for the OETC, provided that throughout the qualifying period substantially all of the employment duties, as referred to in ¶ 3, are performed outside Canada. ...

Principal Issues: Does Bco, a Japanese company, dispose of its assets, including its shares of Cco (a "taxable Canadian corporation" in the oil & gas business in Canada), if Bco merges with Aco (another Japanese company that is Bco's parent) and the corporate law in Japan is of a "continuation type", as described in The Queen v. ... Gosselin Attention: XXXXXXXXXX April 10, 2003 Dear Sirs/Mesdames: Re: Foreign Merger We are writing in response to your request for a technical interpretation dated October 18, 2002 in respect of the tax consequences of a Japanese merger. ... However, we note that the Department of Finance, in the December 2002 Legislative Proposals and Explanatory Notes Relating to Income Tax, has proposed amending the definition of "disposition" in subsection 248(1) of the Act by adding paragraph (n) to exclude certain dispositions of shares which are the result of foreign mergers, and this proposed amendment may apply to the Japanese Merger depending upon the particular situation. ...

However, a 2002 ITA amendment, applicable to the 1997 and subsequent taxation years, established paragraph 110(1)(g) and provides a deduction from income for the amount of certain tuition assistance included in an individual's income pursuant to subparagraph 56(1)(r)(ii). ... In our view, training benefits (including tuition, allowances & books) provided to individuals which are funded under the EI Act are taxable under paragraph 56(1)(r) of the Income Tax Act (the "Act"). ... Paragraph 110(1)(g) of the Act, included in Bill C-49, which received Royal Assent on March 27, 2002 and is applicable to the 1997 and subsequent taxation years, provides that for the purpose of computing the taxable income of a taxpayer for a taxation year, there may be deducted: (g) any amount that (i) is received by the taxpayer in the year under a program referred to in subparagraph 56(1)(r)(ii) or (iii), a program established under the authority of the Department of Human Resources Development Act or a prescribed program, (ii) is financial assistance for the payment of tuition fees of the taxpayer that are not included in computing an amount deductible under subsection 118.5(1) in computing the taxpayer's tax payable under this Part for any taxation year, (iii) is included in computing the taxpayer's income for the year, and (iv) is not otherwise deductible in computing the taxpayer's taxable income for the year Given the fairly recent introduction of the foregoing deduction from income, the availability of a tax exemption for a status Indian may not be as significant a concern as it once was. ...

Plans and Transfers to RRSPs This is in reply to your letter of June 25, 2002, in which you requested clarification of the income tax treatment in respect of amounts received out of or under a particular arrangement described as a U.K. ... This Directorate may only provide written confirmation of the tax implications inherent in particular situations when the transactions involved are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in the Canada Customs and Revenue Agency ("CCRA") Information Circular 70-6R5 dated May 17, 2002 (as updated June 27, 2003). ... Income Tax Convention (the " Convention"). In general terms, Article XVII of the Convention provides that pension payments arising in the U.K. that are paid to a resident of Canada will only be taxable by Canada. ...

As we understand the situation in XXXXXXXXXX e-mail, the Employee's employment was terminated in 2002 as a result of a XXXXXXXXXX. ... A "qualifying amount" received by an individual in a taxation year means, inter alia, "...an amount (other than the portion of the amount that can reasonably be considered to be received as, on account of, in lieu of payment of or in satisfaction of, interest) that is included in computing the individual's income for the year and is (a) an amount (i) that is received pursuant to an order or judgment of a competent tribunal, an arbitration award or a contract by which the payor and the individual terminate a legal proceeding, and (ii) that is (A) included in computing the individual's income from an office or employment, or (B) received as, on account of, in lieu of payment of or in satisfaction of, damages in respect of the individual's loss of an office or employment, (...)." ... Based on the above information provided concerning the years involved, a portion of a retiring allowance that is, in fact, a qualifying amount can be designated on Form 1198 with respect to the year 2002, when the loss of employment occurred. ...

Pension Income This is in reply to your letter of October 15, 2002, in which you requested clarification of whether certain pension payments that you may receive would be taxable. ... This Directorate may only provide written confirmation of the tax implications inherent in particular situations when the transactions involved are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in the Canada Customs and Revenue Agency ("CCRA") Information Circular 70-6R5 dated May 17, 2002. ... Income Tax Convention (the " Convention") applies to exclude the amount. ...

Vous nous demandez nos commentaires sur la répartition du revenu protégé en main d'une société pour les fins de l'application du paragraphe 55(2) de la Loi de l'impôt sur le revenu (ci-après la " Loi ") dans la situation décrite ci-après. ... En effet, en général une action possédée par un actionnaire d'une société ne peut participer au revenu protégé en main gagné que durant la " période de détention " relative à l'action donnée. ... Nous vous soulignons que la présente opinion ne constitue pas une décision anticipée et, tel que mentionné au paragraphe 22 de la Circulaire d'information 70-6R5 du 17 mai 2002, elle ne lie pas l'ADRC à l'égard d'une situation factuelle particulière. ...

Le paragraphe 69(1) de la Loi de l'impôt sur le revenu (la " Loi ") est-il applicable dans le cadre du transfert d'un bien ayant pour objet l'établissement d'un usufruit? ... Nouvelles Techniques No 11 / Income Tax Technical News No. 11. 3. Alinéa 18(1)a) de la Loi / Paragraph 18(1)(a) of the Act. XXXXXXXXXX 2002-018001 Pascal Tétrault Le 31 juillet 2003 Objet: Usufruit d'un immeuble XXXXXXXXXX, La présente fait suite à votre télécopie du 19 décembre 2002 concernant le sujet en titre. ...

Lors de ce décès, l'usufruit d'un immeuble locatif situé en France (ci-après l' " Immeuble ") aurait été dévolu à votre mère, tandis que la nue-propriété de ce même immeuble vous aurait été dévolue. ... Il est à noter à cet égard que l'Immeuble constitue un " bien locatif " au sens du paragraphe 1100(14) du Règlement. ... En terminant, nous vous soulignons que la présente opinion ne constitue pas une décision anticipée et, tel que mentionné au paragraphe 22 de la Circulaire d'information 70-6R5 du 17 mai 2002, elle ne lie pas l'ADRC à l'égard d'une situation factuelle particulière. ...

Since the amount received is included in income, it would not cause the plan to fall outside the guidelines in IT-529. 2 & 4. ... The flex credits would be allocated to the employees before December 1, 2001 for the 2002 plan year, and the selection of benefits would have to be made by this date. ... During 2002, the employer increases the total compensation level of the employee to $60,000. ...