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Your view with respect to this being an anomalous result would more appropriately be addressed to the Department of Finance for their consideration. ...

While you have provided comments which are relevant to the determination of "misuse" or "abuse" we do not feel such a determination can be made without ful consideration of the specific circumstances. ...

That is, any consideration received for the granting of the option is a capital gain to the individual. 2) It is our view that the tax consequences of the subsequent repurchase by the individual who initially granted the option should be governed by paragraph 3 of Interpretation bulletin IT-403R which states that "where the grantor of any option purchases it back from the grantee and they are dealing at arm's length, the Department takes the position that the adjusted cost base of the property to the grantor is generally increased by the amount of the purchase price of the option from the grantee... ...

Nous soumettons ce dossier pour votre considération. pour la directrice Division des services bilingues et des industries d'exploitation des ressources Direction des décisions ...

Where a taxpayer has accrued and reported interest income on a debt obligation and has at any particular time disposed of that obligation for consideration equal to its fair market value at the time of disposition, the taxpayer may, by virtue of subsection 20(21) of the Act, deduct in computing income for the year of disposition, the amount, if any, by which the aggregate of the amounts of interest from that debt obligation that was included in the taxpayer's income for the year of disposition and all previous years exceeds the total interest actually received thereon. ...

A determination of the reasonableness of the amount of remuneration paid to any particular employee requires consideration of the duties performed by the individual, as well as the time spent in carrying out those duties. ...

The MLP is established on the basis of a new car and takes into consideration the cost of the optional features added to the car assuming they are owned by the leasing agency. ...

XXX residential status must then be determined according to the usual considerations as set out in Interpretation Bulletin IT-221. ...

A Registered Pension Fund or Plan is a term defined in subsection 248(1) of the Income Tax Act and reads as follows: "registered pension fund or plan" means an employees' superannuation or pension fund or plan accepted by the Minister for registration for the purposes of this Act in respect of its constitution and operations for the taxation year under consideration;" Since the Pension Plan does not meet the above requirements, the payments made by you to the Pension Plan would not be deductible under the Income Tax Act since they are not made to a Registered Pension Plan. ...

To us the result appears to be anomolous, and accordingly, we are referring the matter to our Provincial and International Relations Division for their consideration of receding a possible amendment to the Act to the Department of Finance. ...