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" This is not, in my opinion, descriptive of the transactions involving letters of credit that are under consideration in this appeal. ...

L’ARC peut prendre en considération la régularité du déplacement et la nature des tâches pour déterminer si un endroit est effectivement le lieu de travail habituel. » Aussi, le Guide de l’employeur T4130 (footnote 3) sous la rubrique « Lieu de travail habituel » indique notamment ce qui suit: « Un lieu de travail habituel est tout endroit où votre employé se présente habituellement pour travailler ou exercer ses fonctions d’emploi. ...

A in Year 2 would not constitute an “excluded amount” and would, absent any other consideration, be considered split income of Mr. ...

These factors, among others, would need to be taken into consideration to determine if the primary purpose of the award is to further the education and training of the recipient or if specific work is being conducted by the student where the primary purpose is to benefit the research activities of the University. ...

Our above view is consistent with CRA’s previous TIs XXXXXXXXXX, which dealt with subsection 403(3), and, in general, opined that the determination of a PE for the reasonable attribution purposes involves consideration of various factors such as the location of origin and servicing of the policies involved and the location which negotiated the contract of reinsurance and on whose books the liability for the risk is recorded (which may be the company's head office in most cases). ...

Other Comments Nothing in this letter should be construed as implying that the CRA has agreed to, reviewed or made any determination in respect of any tax consequences in respect of: (a) the fair market value of any property referred to herein; (b) whether the Proposed Transactions described herein, other than the Proposed Business Transfer, would be undertaken for fair market value consideration; (c) the characterization and tax residency of any entity; (d) any foreign income tax consequences, including whether a rollover provision applies under the Foreign Act; (e) whether any property referred to herein is a “taxable Canadian property”, within the meaning of subsection 248(1), or whether any disposition thereof, including a deemed disposition, could give rise to a taxable capital gain; (f) the potential application of subsection 245(2) to re-determine the tax consequences confirmed in the Rulings given above; or (g) any other tax consequences relating to the facts, Proposed Transactions and additional information described herein, other than those specifically described in the Rulings given above. ...

In determining whether any location visited by a Staff could be a RPE, consideration should be given as to how often a particular townhouse complex or apartment building is visited, and not any individual unit located within the townhouse complex or apartment building. ...

The terms of the settlement provide, among other consideration, for Periodic Payments commencing XXXXXXXXXX, in the amount of XXXXXXXXXX$XXXXXXXXXX per month, increasing by XXXXXXXXXX% annually, guaranteed until the later of XXXXXXXXXX (when the Claimant would turn age XXXXXXXXXX if he dies prior to that date) and the Claimant’s death (XXXXXXXXXX Certain Monthly Payments). 18. ...

Z taking into consideration the application of the deeming rule in subparagraph 120.4(1.1)(b)(ii)? ...

It is important to note the determination of the ACB of the beneficiary’s capital interest in paragraph 107(1)(a) as described above, does not apply if any part of the interest was acquired for consideration and the trust is non-resident at the time of the disposition. ...