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In connection with an arrangement to sell shares payable on an instalment basis, the shares are sold at a predetermined price with a portion of the sale price payable at the time of the sale and the balance to be paid at some future date in two instalments. ...

In order to qualify to claim the OETC an individual must be a resident in Canada in a taxation year and, throughout any period of more than 6 consecutive months was employed by a person who was a specified employer and performed all or substantially all the duties of employment outside Canada: (a)     in connection with a contract under which the specified employer carried on business outside Canada with respect to a qualified activity, or (b)     for the purpose of obtaining, on behalf of the specified employer a contract to undertake a qualified activity. ...

Section 255 of the Canadian Income Tax Act (the "Act") provides that "Canada" is hereby declared to include and to have always included (a)     the sea bed and subsoil of the submarine areas adjacent to the coasts of Canada in respect of which the Government of Canada or of a province grants a right, license or privilege to explore for, drill for or take any minerals petroleum, natural gas or any related hydocarbons: and (b)     the seas and airspace above the submarine areas referred to in paragraph (a) in respect of any activities carried on in connection with the exploration for or exploitation of the minerals, petroleum, natural gas or hydrocarbons referred to in that paragraph. ...

"Canada" is hereby declared to include and to have always included (a)     the sea bed and subsoil of the submarine areas adjacent to the coasts of Canada in respect of which the Government of Canada or of a province grants a right, license or privilege to explore for, drill for or take any minerals, petroleum, natural gas or any related hydrocarbons; and (b) the seas and airspace above the submarine areas referred to in paragraph (a) in respect of any activities carried on in connection with the exploration for or exploitation of the minerals, petroleum, natural gas or hydrocarbons referred to in that paragraph. ...

You will also note that the above comments are consistent with the following explanatory note released by the Department of Finance (May, 1991) in connection with the amendment: This paragraph is amended to clarify that, for this exemption to apply, the food, beverages or entertainment must be generally available to all employees at a particular location of the employer and consumed or enjoyed by such employees. ...

Some concerns have been raised in this connection regarding the Goods and Services Tax Credit and you are seeking answers to questions which you have posed. ...

The filing of a U.S. return or the allocation of any portion of its taxable income to the United States may be indicative of whether or not the specified employer is carrying on business in the United States in connection with the particular contract. ...

It is our understanding that, in connection with an arrangement to sell shares on an instalment basis, the shares are sold at a predetermined price with a portion of the sale price payable at the time of the sale and the balance to be paid at some future date in one or more instalments. ...

Although the casualty company must remain the beneficiary under the annuity contract, all payments under the contract must be irrevocably directed by the casualty company to be made to the plaintiff. e)     A confirmation must be made that the issues involved in the ruling request are, to the best of the taxpayer's knowledge and/or his/her representative's knowledge, not being considered by a District Office and/or Taxation Centre in connection with a tax return already filed, or subject to an objection or appeal. ...

The payment would be made to compensate the trusts for substantial unrealized losses in connection with the acquisition of certain common shares comprising the majority of the trusts' assets. ...