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

With respect to the question of a "reasonable" allowance under the proposed amendments, it is our tentative view that such questions will be determined on a case by case basis, taking into consideration each employee's circumstances. ...

However, the Convention defines pension as periodic payments made in consideration for part services. ...

Having thus concluded, it is our further opinion that the provisions of subsection 74(3) of the Act are applicable to the arrangement under consideration which would exclude the fee from the wife's income and preclude its deduction from her husband's income. ...

This position is reinforced in paragraph 12 of Interpretation Bulletin IT-341R which will be released in the near future. b) Paragraph 1 of Interpretation Bulletin IT-99R states that legal expenses will generally be deductible if they are incurred for the purpose of gaining or producing income from a business or property and they are not outlays of a capital nature. c) Paragraph 5 of Interpretation Bulletin IT-239R and paragraphs 6 and 11 of Interpretation Bulletin IT-239R2 deal with the Departmental practice concerning capital losses where a shareholder guaranteed a loan for his company for no consideration and subsequently, he makes a payment of a capital debt under the guarantee. d) Provided that a loss qualifies as a capital loss within the assessing of paragraph 39(1) (b) of the Act and provided that the conditions of paragraph 39(1) (c) of the Act are satisfied, the loss will qualify as a business investment loss. ...

We have also referred a copy of this memo to Assessing Division in head Office for their consideration as to whether comments concerning such situations should be included in T.O.M. for Director Non-Corporate Rulings Division 251(1)(b) 110.1 ...

Accordingly, we have taken the liberty of forwarding a copy of our correspondence to the Department of Finance which has the responsibility for the consideration and recommendation of amendments to the Income Tax Act. ...

In response to a recent enquiry we have given further consideration to this matter and it is now our view that we should revert back to the position set out in our December 20, 1976 memo. ...

Lease Inducement Payments This issue is currently under consideration and we will notify you by telephone as soon as it is resolved. ...

We appreciate that the tax return at present does not allow for much flexibility, but we believe some consideration should be given to this problem. ...