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With respect to the issue of whether the recipient is required to include his world wide income or just his periodic pension payments arising in Canada in determining the rate of tax to be applied under paragraph 2 of Article XIX of the Convention on those particular sources of income, we are of the opinion that it is the recipient's world wide income that must be taken into consideration. ...

The wording of subsection 147.2(2) of the Act does not in our view preclude an actuary from stating a minimum amount and a maximum amount required to fund an RPP and recommending that the plan sponsor contribute an amount between the two, provided the maximum amount does not exceed that determined under subsection 147.2(2) of the Act after taking into consideration paragraphs (c) and (d) thereof. ...

Income Tax Convention This is in response to your memorandum of June 1, 1993 wherein you requested our views concerning section 180.2 (Part I.2) of the Income Tax Act (the "Act") in the following fact situation concerning XXXXXXXXXX (the "taxpayer"), who has requested Competent Authority consideration in respect to the following set of facts. ...

A transfers all of his shares of Company A to Company X and receives as consideration therefore, 55% of the voting shares of Company X, a taxable Canadian corporation. 3.      ...

Consequently it is our opinion that an agent would normally fall within the ambit of subsection 159(2) in most practical situations, including the case under consideration. ...

Humenuk   957-2135   File No. 0-0146 Subject: Project November 1507 Retiring Allowances Revision of IT-337R2 We have reviewed version 6 of the draft revision to the above noted bulletin and offer the following comments for your consideration. ...

The comments in this letter are of a general nature only and do not take into account considerations that might arise in connection with a specific transaction or event. ...

In particular, you ask the following: 24(1) Assumptions We assume that: 1)     24(1) Our Opinion 1)     With regards to the transaction in paragraph 12 above, subsection 23(3) of the OBCA provides that a corporation may not issue a share of its capital until the consideration for the share is fully paid in "money or in property... ...

If the payment in question does not qualify for this treatment, consideration should be given to whether the payment is a death benefit as defined in subsection 248(1) of the Act, a pension benefit or a payment from a group term life insurance policy.  ...

Concernant l'application de l'article 103 de la Loi, nous sommes d'avis qu'il est raisonnable de considérer que l'allocation n'avait pas pour objet principal de réduire les impôts ou d'en différer le paiement étant donné que les parties n'étaient pas liées, qu'il y avait certainement des considérations de nature commerciale qui ont mené les parties à faire cette allocation et  24(1) C.      ...