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Reasons: It is unlikely that the CRA’s administrative position regarding the income tax treatment of reimbursed house hunting costs, legal fees, or land transfer taxes would be affected in situations where there is a delay or gap between the time an individual incurs the expenses and an employer reimburses those expenses, provided that it is reasonable to conclude that the expenses were incurred in connection with the move. ... In our view, the non-taxable treatment of such reimbursements would not be affected when there is a delay between the time an employee incurs the expense and the employer provides a reimbursement for that expense, provided that the particular expense was incurred in connection with the relocation. ...

In connection with the FTS offering, the Issuer may retain an underwriter (an “Underwriter”) to assist it with finding Investors to participate in the Issuer’s FTS offering and to provide other related services, in consideration for which the Issuer will pay the Underwriter a fee which may be in the range of 3 to 6% of the FTSs subscription price (an “Offering Assistance Fee”). ... YOUR QUESTION You have asked whether, in a circumstance where the Issuer does not retain an Underwriter in connection with its FTS offering, the payment by the Issuer to the Promoter of an Offering Assistance Fee as consideration for the Promoter assisting the Issuer with finding Investors to participate in the FTS offering and providing other related services, would result in the FTSs issued under that FTS offering becoming prescribed shares within section 6202.1 of the Regulations. ...

This position also applies to amounts received at any time in connection with the termination of coverage under a PHSP provided by an employer whose insolvency arose before 2012. ... However, for lump sum amounts received in 2012 and later years, other than amounts received in connection with an insolvency that arose before 2012, it is the CRA’s revised position that these amounts are generally considered to be taxable as employment income pursuant to paragraph 6(3)(b) of the Act, and subject to deductions at source. ...

However, in determining whether a property is a tax shelter for the purposes of section 237.1 of the Act, the calculation of deductible losses and other deductible amounts is to be made on a prospective basis based upon statements or representations made or proposed to be made in connection with that property. If it may reasonably be considered, having regard to the statements and representations made or proposed to be made in connection with the property, that a purchaser will be entitled to deduct losses or other amounts in excess of the cost of the interest in the property to the purchaser at the end of any particular year after the deduction of prescribed benefits, then the property is a tax shelter. ...

Since you have not requested an advance income tax ruling, our comments are of a very general nature and should not be taken as exhaustive of all the possible income tax consequences that can arise in connection with the proposal. ... Rental Recapture Rule If a farmer exercises his purchase option, a special rule set out in subsection 13(5.2) of the Act applies to rentals previously deducted by the farmer (or by a non-arm's length person) in connection with the property.  ...

The word "conjunction" is defined ln The Oxford English Dictionary to mean "joining together, marriage union, connection of ideas,...the action of conjoining; the fact or condition of being conjoined; union, connection, combination... ...

These rules are applicable after October 8, 1986 except that with respect to a plan or arrangement established before October 9, 1986 or established after October 9, 1986 pursuant to an agreement between a taxpayer and an employer or former employer of the taxpayer entered into before October 9, 1986 (referred to as the "existing arrangement"), for the purposes of the Act, (a)     another plan or arrangement (referred to as the "statutory arrangement") is deemed to be established on the day that is the earlier of January l, 1988, and the date after October 8, 1986 on which the terms of the existing arrangement have been materially altered; b)     the statutory arrangement is deemed to be a separate arrangement independent of the existing arrangement; (c)     the existing arrangement is deemed not to be a retirement compensation arrangement; and (d)     all contributions made under the existing arrangement after the establishment of the statutory arrangement and all property that can reasonably be considered to derive from those contributions are deemed to be property held in connection with the statutory arrangement and not in connection with the existing arrangement. ...

Shinerock   (613) 957-2108 19(1) June 10, 1992 Dear Sirs: Re:     Subsection 55(2) of the Income Tax Act (the "Act") We refer to your letter of November 20, 1991, in which you requested a technical interpretation of the provisions of subsection 55(2) of the Act in connection with the payment of a dividend out of income earned or realized by a corporation after 1971 ("Safe Income"), as referred to in subsection 55(2) of the Act, in connection with the facts assumed in the hypothetical situations described below. ...

Reasons: Depending on the facts of the situation, where there is a discernable connection between the two events (i.e., the death of the parent and the disposal of the housing unit by the child beneficiary), such that it may be possible to conclude that the disposition of the housing unit by the taxpayer can reasonably be considered to have occurred due to the death of a related person, the disposition may be excluded from the application of the flipped property rules in subsections 12(12)-12(14). ... However, if it can be shown that there is a sufficiently clear connection between the death of the deceased parent and the disposition of the housing unit by the child beneficiary, then it may be possible to conclude that the disposition of the housing unit by the child beneficiary can reasonably be considered to have occurred due to the deceased parent’s death, and the gain realized on the disposition would not be deemed to be business income by virtue of the application of subsection 12(12) of the Act. ...

An amount received in respect of a scholarship or bursary in connection with the taxpayer's enrolment in an elementary or secondary school educational program is specifically excluded from income under subsection 56(3) of the Act. ...