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" The first consideration should therefore be to determine the purpose of the legislation, whether as a whole or as expressed in a particular provision. ...

In its ordinary meaning, a pension is a payment to be made to a person by the person's former employer or by a government authority in consideration of past services. ...

However, the Act provides that a RRIF may only accept property as consideration (ie, a contribution) where it is directly transferred from one of several types of arrangements including an RRSP. ...

In addition we are currently giving consideration to providing for some grandfathering for insurance arrangements entered into before the issue date of IT-430R3 (February 10, 1997) in respect of which the creditor is the beneficiary of an insurance policy intended to secure the indebtedness of a debtor. for Director Financial Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

We recognize that there may be other issues or considerations which may arise in connection with an actual case. ...

The Department states in paragraph 12 of IT-396R, that interest has been described in general terms in the courts as "the return or consideration or compensation for the use or retention by one person of a sum of money, belonging to, in a colloquial sense, or owed to, another". ...

Section 94.1 of the Act could also apply if, after the beneficiary has resided in Canada for 60 months, the trust is subject to either paragraph 94(1)(c) or (d) of the Act and the beneficiary continues to participate in the Plan and one of the main reasons for acquiring, having or holding the interest in the trust was motivated by the tax considerations as described in subsection 94.1(1) of the Act. ...

In the Department's view, the guidelines set out in this Interpretation Bulletin are a reasonable distillation of the relevant considerations developed by the Courts. ...

Des facteurs comme les suivants sont pris en considération pour déterminer si une entreprise est exploitée principalement au Canada: le genre d'entreprise, la proportion des services rendus et du bénéfice net attribuable au Canada et l'étranger, la localisation des actifs, les pays où les contrats sont conclus, le nombre d'employés affectés au Canada et à l'étranger. ...

Accordingly, the payment of an annual block fee would not be a qualifying medical expense under paragraph 118.2(2)(a) of the Act, nor would it qualify as a "premium, contribution or other consideration" pursuant to 118.2(2)(q) of the Act. ...