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We would point out that because a retiring allowance must be paid upon or after retirement your main concern appears to be whether or not the husband and/or wife would be considered retired as at cessation of their retail store operation even though the company continues. ...

However, we agree with the opinion given to the joint committee that for purposes of 110.6 a partner will be considered to have disposed of property where the partnership in fact disposes of the property. ...

Accordingly, we agree that the "number of years" in your example for purposes of clause 60(j.1)(ii)(A) of the Act would be considered to be 15 years. ...

The payment of such expenses by your RRSP may be considered a benefit paid to you thus causing the deregistration of the plan. ...

It is also our view that a person will not generally be considered to have retired from, or lost, his office or employment where control of his employer has changed but he has been retained in his same or another position with the employer. ...

Accordingly, it is our view that this is a matter which should be considered only by way of an advance income tax ruling. ...

Accordingly, it is our opinion that an amount which is paid before the end of the 180th day can be considered to be paid within the time limit stipulated by subsection 78(4) of the Act. ...

These amounts are currently being considered for remission by us, under the Financial Administration's Act. ...

The amount of the contribution is equal to the fair market of the letter of credit which is a question of fact; however, such factors as the date the letter of credit becomes payable, the credit worthiness of the employer, the restrictions on payment, the intent of the parties to the transaction etc. would have to be considered. ...

The greater the difference between the relevant commercial interest rate at the time of the loan and the interest rate offered, the more likely the participation payments will be considered equity payments as opposed to interest payments. ...