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Le problème soulevé par l'application du paragraphe 75(2) de la Loi aux fiducies régissant les conventions de retraite dans une situation telle que celle décrite ci-haut a été soumis au ministère des Finances pour leur considération par notre division des modifications courantes. ...

Where an employer wishes to extend non-qualifying benefits as well as those which do qualify for inclusion in a private health services plan, consideration should be given to providing the non-qualifying benefits through a separate plan, thereby preserving the tax free status of the benefits which do qualify for inclusion in a private health services plan. ...

Where subsection 84.1(1) of the Act applies, and where the sole consideration received by an individual (hereinafter referred to as the transferor) for the subject shares consists of shares of the purchaser corporation, there will be a reduction of the paid-up capital of the shares of the purchaser corporation received by the transferor as a result of the transfer if such paid-up capital is greater than the greater of the paid-up capital of the subject shares and the adjusted cost base, as determined under paragraphs 84.1(2)(a) and (a.1) of the Act, to the transferor of the subject shares. ...

Many factors such as the amount of the investor's original investment, the partner's previous income or losses from the partnership, the amounts of any revenue guarantees and the amount of any non-arm's length loans, are taken into consideration. ...

An important factor in this consideration could be the nature of the underlying property in the trust, and whether that property would be viewed as being located on a reserve if considered on its own merits. ...

Alternatively, where it is determined, after consideration of all the relevant circumstances, that a particular payment to an employee is an advance on account of future salaries, section 80.4 does not apply. ...

Our Comments In order for a particular direct reimbursement dental plan ("DRDP") to qualify as a Private Health Services Plan ("PHSP"), as defined in subsection 248(1) of the Act, the plan implemented by an employer on behalf of its employees must be in the nature of insurance and must contain the following elements as set out in paragraph 3 of the attached Interpretation Bulletin, Private Health Services Plans IT-339R2: (i) an undertaking of one person, (ii) to indemnify another person, (iii) for an agreed consideration, (iv) from a loss or liability in respect of an event, (v) the happening of which is uncertain. ...

We thank you for bringing this matter to our attention which is being forwarded to the Department of Finance, through our Current Amendments and Regulations Division, for their consideration. ...

There has not been any land sales in the years under consideration and neither has there been any development on the lands in question. ...

" The matter has been referred to the Department of Finance and we will not issue rulings or opinions while the issue is under consideration. ...