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It would be appreciated if you could outline your position and interpretation concerning this matter so we may be in a position to reply to the many Canadian residents who are writing us asking for information in this connection. ...

The type of assistance provided is a lump sum allowance based on the distance to be travelled and is intended to provide for assistance to persons who are moved from one place in Canada to another place in Canada in connection with the Canada Mobility Program. ...

In connection with the situation where goodwill is sold and there is uncertainty as to when an amount will be paid or there is to be a delay of several years in payment, it is our position that the proceeds of disposition as determined in the year of sale are considered to constitute an amount that "became payable" for the purposes of section 14 and that a reserve is not available with respect to anticipated future receipts or with respect to an allowance for doubtful amounts. ...

It is our opinion that all of your officers engaged in obtaining documentation in connection with the class 34 certification process are subject to the provisions of subsection 241(1) of the Act since you are obtaining this information on behalf of the Minister of National Revenue Furthermore, your officers are regarded as officials or authorized persons thereunder since they are clearly such persons by virtue of the definitions in paragraphs 241(10)(a) and 241(10)(b) respectively. ...

By way of exception, the same paragraph provides that wherever the payer may be resident, if he has a permanent establishment in one of the states in connection with which the indebtedness on which the interest is paid was incurred, and that interest is borne by that establishment, then the interest is deemed to arise in the state in which the permanent establishment is situated. ...

We understand that to the best of your knowledge and that of XXXX officials, none of the issues involved in this opinion request is being considered by a District Office or a Taxation Centre in connection with a tax return already filed, and none of the issues is under appeal or objection. ...

We have been informed that the payments by Hydro in connection with this program involved many customers and totalled over $300 million. ...

In connection with the IRA, we have said that, by virtue of subsection 75(2), the income of the trust would be taxable in the hands of the beneficiary. ...

It should be noted in connection with this that subsection 10(6) of the 1971 Income Tax Application Rules explains that any reference in a tax convention to a rate higher than the rate stipulated in a tax convention is, with respect to the payments made to a resident of the other country, to be interpreted as a reference to the rate stipulated in the tax convention. ...

In this connection, paragraph 6 of Interpretation Bulletin IT-239R2 sets out the circumstances and conditions under which a loss resulting from, among other things, the payment of a debt under a guaranty for which the guarantor received insufficient consideration, is not considered by the Department as a nil loss under subparagraph 40(2)(g)(ii) of the Act. ...