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In addition to the Interpretation Bulletins to which reference is made in our letter, you may wish to refer to VC- 89-3 on research grants concerning factors to be considered in determining the nature of the income. ...

However, we find in this instance that any such comments would no be of further assistance to you inasmuch as they would essentially repeat those comments contained in Interpretation Bulletin IT-305R3 which, as indicated in your letter, you have already considered. ...

Notwithstanding Revenue Canada's position in paragraph 20 of Information Circular 76-19R, it is your opinion that a prepaid expense would be property that qualifies for a rollover under section 85 of the income Tax Act (the "Act") if two conditions are met: 1) the prepaid expense can be considered to be a right, and 2) a cost amount is affixed to this right. ...

A refund of an employee's contributions would be considered to be pension benefits for purposes of subparagraph 56(1)(a)(i). ...

Both Her Majesty in the right of P.E.I. and the 24(1) could be considered qualified donees for purposes of section 110.1 of the Act. ...

A report is required in accordance with TOM 2263.24(2) detailing any information which may assist us with our review as well as your recommendation as to whether a remission should be favourably considered. ...

Generally, a trust is considered to reside where the trustee who manages the trust or controls the trust assets resides. ...

The coat of significant repairs or major alterations that are capitalized are considered an acquisition in the awe sense that an addition in a subsequent period, to a previously purchased building would be. ...

We also feel that subsection 56(2) is inapplicable in the circumstances because the Courts have held that intercompany loans were not considered payments or transfers of property. ...

As indicated in item 3 of our March 14, 1989 letter, interest earned on a participating employee's deferred salary under the Plan for a year is considered to be employment income for that year. ...