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Jack Szeszycki RE: Deferred Salary- Leave Plan As discussed by telephone we are forwarding the attached correspondence received from the Thunder Bay District Office for your consideration. ...

The classification of such a transfer is a question of fact to be determined after consideration of all the relevant circumstances. ...

Burnett who suggested that this be referred to your Directorate so that it may be forwarded to the Department of Finance for their consideration. ...

We would also comment that where the agreed consideration for a PHSP is regarded as being the employees' covenants as found in the contract of service between the employer and the employee, it is our view that the arrangement should cover all employees (or all employees within a specific employee category) in one plan with the same coverage extended to each employee. ...

Jack Szeszycki RE: Deferred Salary- Leave Plan As discussed by telephone we are forwarding the attached correspondence received from the Thunder Bay District Office for your consideration. ...

Where such a ruling is requested full details, including all pertinent documents, of the proposed plan, must be submitted for consideration. ...

You will note that Canadian citizenship has no bearing on the determination of residency and is not a consideration in the Income Tax Act. ...

We trust that the foregoing remarks will be of assistance to you but please do not hesitate to refer for our consideration any particular case which presents a problem Chief Technical Section TMcD/mh ...

Workload constraints prevented us from giving full consideration to your query until this time. ...

Paragraph 20(1)(bb) requires consideration in the case of those fees charged to capital account and fees charged to income account that were not laid out to gain or produce income but were outlays on account of capital. ...