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., a distributor) could be considered to have acquired all beneficial ownership rights in the copyright in a production, if the production company grants to that third party all of the revenues from the distribution or the right to distribute or otherwise exploit the film in markets representing most or all of the exploitable value of the film. ...

However, certain criteria such as the distribution of income, assets and workforce of each activity will be considered in making that determination. ...

However, certain criteria such as the distribution of income, assets and workforce of each activity will be considered in making that determination. ...

In finding that each Corporation had a personal services business (PSB), the Directorate considered that X controlled the work of the individual shareholders and that the Corporations’ operations were integrated into the business of X. ...

. … [A] partnership would generally be considered a "taxpayer" for the purposes of subsections 51(1), 85.1(1) and 86(1) and would therefore be entitled to rely on the rules contained therein …. ...

. … [A] partnership would generally be considered a "taxpayer" for the purposes of subsections 51(1), 85.1(1) and 86(1) and would therefore be entitled to rely on the rules contained therein …. ...

However, where an individual receives a lump sum payment in lieu of future benefits that would have been otherwise paid under an employer long-term disability plan, in circumstances such that the payment can reasonably be considered to be proceeds of disposition of an interest in an insurance policy, it is our view that the proceeds are not taxable under paragraph 6(1)(f) of the Act or as a capital gain pursuant to subparagraph 39(1)(a)(iii) …. ...

31 January 2006 External T.I. 2005-0151041E5 F- Régimes de sécurité sociale étrangers-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 plan recognized as a pension plan under Art. 29(5) of the Cda-France Convention cannot be an EBP In response to a query as to whether contributions made by an employer to certain French social security plans are considered taxable benefits to employees who are residents of Canada for a period not exceeding 5 years and an expressed view that such plans are employee benefit plans ("EBP") so that no amount is to be included in the employee's income as a benefit under s. 6(1)(a)(ii), CRA stated: [W]here a pension plan is recognized for the purposes of paragraph 5 of Article 29 of the [Canada-France] Convention, it is our view that it is not an EBP. ...

27 January 2006 External T.I. 2005-0164611E5 F- Société immobilière de pension- sens de location-- summary under Clause 149(1)(o.2)(ii)(A) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(ii)- Clause 149(1)(o.2)(ii)(A) providing meals, medical services and housekeeping in a seniors apartment would put the corp. offside Regarding whether a pension fund real estate corporation that owns (in joint tenancy with a taxable corporation) a building that includes apartments rented to independent seniors can be considered to have limited its activities to the leasing or managing of capital property that is real property for the purposes of clause 149(1)(o.2)(ii)(A) if it provides meals, medical services and housekeeping that are billed separately, CRA stated: [T]he services provided by the Corporation … do not constitute leasing or managing capital property for the purposes of clause 149(1)(o.2)(ii)(A). ...

In its summary, it stated: The distribution by the spousal trust to the foundation was made in accordance with the terms of the testator’s will and therefore, the spousal trust would not be considered the donor. ...