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Position: No Reasons: Subparagraph 146(5)(a)(iv.1) prohibits a deduction for a premium considered to be withdrawn as an eligible amount within 90 days. 5-970814 XXXXXXXXXX Franklyn S. ...

This will serve to confirm that it is our view that where the annuitant makes a payment to his or her RRSP trust as a contribution under the trust to be applied for the purpose of providing the annuitant with a "retirement income" (as defined in subsection 146(1) of the Act) on maturity, the payment is considered a payment of a "premium" as defined in subsection 146(1) of the Income Tax Act unless it is a payment excluded in the conclusion to that definition. ...

TEI Conference 1996 Round Table Question XIX- OVERSEAS CREDIT In a technical interpretation dated April 18, 1995 (document number 9500997), Revenue Canada stated that an employer will not be considered to be carrying on business in another country with respect to one of the specified types of activities set forth in clause 122.3(1)(b)(i)(B) of the Act unless the activity is the principal activity of the employer. ...

Each election, however, would be considered on its own merits. We trust our comments will be of assistance to you. ...

IT-506 is currently under revision and your comments regarding non-resident trusts and subsections 20(11) and 20(12) will be considered. ...

Principal Issues: limited partners carrying on business Position: limited partner considered to be carrying on business provided limited partnership carries on active business Reasons: admin position S. ...

Principal Issues: Whether an amount of income of a foreign affiliate which "shall not be included in computing the income" of a foreign affiliate of a taxpayer pursuant to paragraph 81(1)(c) of the Act can be considered to be "subject to tax under Part I of the Act" for the purposes of paragraph 5906(1)(b) of the Regulations to the Act. ...

It is important to remember that our file no 963480 gives only general guidelines permitting a VCC to make a 39(4) election, and, as we stated in our last letter to you, each election would be considered on its own merits. ...

This bulletin indicates that tuition fees paid for, or reimbursed by an employer are not considered to be a taxable benefit if the principal beneficiary of the training is the employer. ...

The amount of the net taxable capital gains that may be designated to a particular beneficiary is limited to the portion of the net taxable capital gains as may reasonably be considered having regard to all circumstances, including the terms and conditions of the trust arrangement, to be part of the amount included in computing the beneficiary’s income for the taxation year under subsection 104(13) or (14) or section 105. ...