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Finance's Response We agree with the CRA that an unfunded SERP that provides unreasonable benefits should be considered to be an SDA, and that the determination of "reasonableness" in this context can require the consideration of any number of factors the relevance of which will depend on the particular circumstances. ...

In consideration of the Insurer making such payments, the Plaintiff settles XXXXXXXXXX claims against the Defendant. ...

XXXXXXXXXX your question regarding the above-mentioned matter was referred to me for consideration. ...

Where there is a farming business carried on, determining considerations include whether the rental activities constitute a separate activity or business, and, whether the leasing income and activity is incidental to the farming income and activity. 2007-025421 XXXXXXXXXX James Atkinson CGA (519) 457-4832 December 11, 2007 Dear XXXXXXXXXX: Re: Lease of Quota- Farming or Rental Income This is in response to your fax of September 27, 2007 inquiring about the characterization of income from the lease of farm quotas. ...

In view of the above, we will bring this matter to the attention of the Department of Finance for consideration as to whether a legislative change is necessary. ...

The definition of "excluded obligation" in subsection 6202.1(5) of the Regulations provides that: "excluded obligation", in relation to a share issued by a corporation, means (a) an obligation of the corporation (i) with respect to eligibility for, or the amount of, any assistance under the Canadian Exploration and Development Incentive Program Act, the Canadian Exploration Incentive Program Act, the Ontario Mineral Exploration Program Act, 1989, Statutes of Ontario 1989, c. 40, or the Mineral Exploration Incentive Program Act (Manitoba), Statutes of Manitoba 1990-91, c. 45, or (ii) with respect to the making of an election respecting such assistance and the flowing out of such assistance to the holder of the share in accordance with any of those Acts, (a.1) an obligation of the corporation, in respect of the share, to distribute an amount that represents a payment out of assistance to which the corporation is entitled (i) under section 25.1 of the Income Tax Act, Revised Statutes of British Columbia, 1996, c. 215, and (ii) as a consequence of the corporation making expenditures funded by consideration received for shares issued by the corporation in respect of which the corporation purports to renounce an amount under subsection 66(12.6) of the Act, and (b) an obligation of any person or partnership to effect an undertaking to indemnify a holder of the share or, where the holder is a partnership, a member thereof, for an amount not exceeding the amount of any tax payable under the Act or the laws of a province by the holder or the member of the partnership, as the case may be, as a consequence of (i) the failure of the corporation to renounce an amount to the holder in respect of the share, or (ii) a reduction, under subsection 66(12.73) of the Act, of an amount purported to be renounced to the holder in respect of the share. ...

Vous désirez savoir si la totalité des intérêts payés par X inc. et Y inc. seront déductibles dans le calcul de leur revenu en prenant en considération que X et Y détiennent aussi personnellement des actions dans le capital-actions de XY inc. 2. ...

A plan in the nature of insurance, in this respect, must contain the following basic elements: (a) an undertaking by one person, (b) to indemnify another person, (c) for an agreed consideration, (d) from a loss or liability in respect of an event, (e) the happening of which is uncertain. ...

Since your situation seems to involve specific taxpayers and completed transactions, you may submit the specific details, to the appropriate tax services office for their consideration. ...

The determination would generally take into consideration the degree of involvement of the individual's employer in securing the loan, for example, whether the employer provides documentation to the lender to support the employee's loan application, guarantees the principal and/or interest, and pays the interest subsidy to the lender. ...