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Our understanding of the facts of your situation are as follows: 24(1) 24(1) In connection with the questions you have asked, we wish to note that based on the above information provided to us, the Fund, in our view, is an "employee benefit plan" pursuant to the definition of this term in subsection 248(1) of the Income Tax Act (the Act).  ...

In our opinion, the interest paid by USCo to Canco on the loan made by Canco to USCo would be considered to be interest and taxable as such under the Income Tax Act and Canco would not be entitled to a deduction under section 113 of the Act in connection therewith, irrespective of whether such interest is re-characterized and deemed to be a dividend by and for the purposes of the United States Internal Revenue Code. ...

For example, subparagraph 184(1)(b)(iii) of the Canada Business Corporations Act ("CBCA") states that on a vertical short-form amalgamation "no securities shall be issued by the amalgamated corporation in connection with the amalgamation". ...

Baumeister (613) 995-0051 January 18, 1982 Dear Sirs: This is in reply to your letter of December 8, 1981, in connection with the deductibility of certain fees paid by an annuitant to the trustee of his self-administered RRSP. ...

In this connection, you wish to know if a loss incurred in the following circumstances is a business investment loss pursuant to paragraph 39(1)(c) of the Income Tax Act (the "Act"): XXXX We confirm that after the divorce the taxpayer and his former wife are not related for purposes of the Act but wish to advise that paragraph 251(1)(b) of the Act states "it is a question of fact whether or not persons not related to each other were at a particular time dealing with each other at arm's length". ...

Subsection 67.1(1) of the Act contains the words "in respect of" which we interpret to mean in relation to or in connection with. ...

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. ...