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We doubt whether the workers would be considered to be employed in "international traffic" as the vessels are used primarily for moving goods and services between a Canadian port and a drill ship. ...

However, the Department's general position as set out in paragraph 12 of Interpretation Bulletin IT-218R is as follows: Vacant land that is capital property used by its owner for the purposes of gaining or producing income will be considered to have been converted to inventory at the earlier of a) the tine when the owner commences or causes the commencement of improvements thereto with a view to selling it, and b) the time of making application to the relevant authority for approval of a plan to subdivide the land into lots for sale, provided that the taxpayer proceeds with the development of the subdivision. 2. ...

On the basis that such copper has previously been processed to the prime metal stage, we are of the opinion that the resultant production and related costs should be considered processing and not production. ...

As we previously pointed out in our letter of January 4, 1978, lump sum payments or proceeds received by a corporation under the terms of a disability policy would be considered proceeds from the disposition of a capital property and therefore subject to the capital gains provisions. ...

In such situations, provided that the foreign currency is converted to an otherwise qualified investment within a reasonable time (for example, 1 month), it would not be considered to be a non-qualified investment acquired by the RRSP We trust this is satisfactory. ...

It should be noted that it is our view that an agreement to issue or sell shares which is conditional upon a future event, for example, attaining an annual performance target, would not be considered such an agreement for the purposes of section 7 of the Act until the conditions specified in the agreement are fulfilled. ...

THE APPLICATION OF ANTI-AVOIDANCE RULES ARE CONSIDERED BY OUR AUDIT STAFF AND APPLIED IN APPROPRIATE CASES. ...

We have not examined the various accounts which may be maintained by such taxpayers and have no guidelines that the inclusion of a security in a particular account by a life insurer would automatically result in sale proceeds being considered on income or capital account. ...

As indicated in paragraph 9, provided that the principal reason for owning your home was not for the purpose of gaining or producing income therefrom, you would be considered to have "ordinarily inhabited" the home in a particular year notwithstanding that you only inhabited it from May to October of the year. ...

Reimbursements for legal costs which were essential in respect of and directly relate to the conduct of an action for wrongful dismissal will not, to the extent that such legal costs were actually incurred by the taxpayer, be considered to form part of the retiring allowance. ...