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You requested that such determination be made in connection with the following facts: a) Mr X is the sole shareholder of a Canadian operating company ("Opco"); b) Mr. ...

" In general terms, the conditions set out in paragraph 149(1)(l) of the Act with which a club, society or association must comply in order to qualify for exemption as a non-profit organization are as follows: (a) it must not, in the opinion of the Minister, be a charity; (b) it must be organized exclusively for social welfare, civic improvement, pleasure, recreation or any other purpose except profit; (c) it must in fact be operated exclusively for the same purpose in (b) for which it was organized or for any of the other purposes mentioned in (b); and (d) no part of its income may be paid, payable or otherwise made available for the personal benefit of any proprietor, member or shareholder, except in connection with the promotion of amateur athletics in Canada. ...

" In general terms, the conditions set out in paragraph 149(1)(l) of the Act with which a club, society or association must comply in order to qualify for exemption as a non-profit organization are as follows: a) it must not, in the opinion of the Minister, be a charity; b) it must be organized exclusively for social welfare, civic improvement, pleasure, recreation or any other purpose except profit; c) it must in fact be operated exclusively for the same purpose in (b) for which it was organized or for any of the other purposes mentioned in (b); and d) no part of its income may be paid, payable or otherwise made available for the personal benefit of any proprietor, member or shareholder, except in connection with the promotion of amateur athletics in Canada. ...

However, we can provide the following general comments on the taxation of amounts received in connection with GIC investments. ...

XXXXXXXXXX Frank Fontaine, FCCA 2001-010983 February 28, 2002 Dear XXXXXXXXXX: This is in reply to your letter dated November 5, 2001 requesting our technical interpretation in connection with the meaning of the term "government assistance", as defined in subsection 127(9) of the Income Tax Act (the "Act"). ...

It also requires that the employer is an Indian band which has a reserve, or a tribal council representing one or more Indian bands which have reserves, or an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves, and that the duties of the employment are in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserve. ...

(Our emphasis added) Since the cancellation of IT-114, the CCRA has not issued any bulletins on the taxation of discounts, premiums and bonuses in connection with obligations. ...

Further, the student may not be in receipt of income from an office or employment if attending the program in connection with or as part of the duties of that office or employment. ...

If you are considering these issues in connection with specific transactions, you may wish to submit a request for an advance income tax ruling in the manner set out in Information Circular 70-6R3, Advance Income Tax Rulings. ...

Nevertheless, we offer the following general comments in connection with your request. ...