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We agree with your position that a plan could be considered a "salary deferral arrangement" as that term is defined under subsection 248(1) of the Income Tax Act (the "Act") notwithstanding that the "deferred amount" is not included in income by virtue of the transitional rules contained therein. ...

With regard to III above, it is our opinion that such an agreement would not be considered normal commercial practice unless the agreement does not cover a period exceeding a period after which a commercial lender would initiate collection/legal action. ...

We apologize for the delay in responding to your inquiry which arose because we considered it necessary to undertake consultations with the Department of Finance in connection with this matter. ...

In our opinion, on the acquisition of the properties by the amalgamated corporation pursuant to the agreement, the exception provided in subsection 66.6(2) of the Act will be considered to apply to the amalgamated corporation. ...

The deductibility of premiums, the timing of any such deduction and the treatment of investment income are all issues that need to be considered in circumstances where members of the exchange are other than tax-exempt entities. ...

Further, any benefits paid to employees under a non-trust arrangement would be considered as ordinary employment income and taxable under subsection 5(1) of the Act. ...

The Super Allowance, the Current Cost Adjustment and the related provincial tax savings are not considered "government assistance" as that term is defined in paragraph 127(9) of the (Canadian) Income Tax Act (the "Act"). ...

Sheerin (613) 957-2135 Attention: Naomi Tsuji Section 148-14 Business Enquiries Group RE: XXXX Whether Bridging Supplement Qualifies as a "Retiring Allowance" This is in reply to your memorandum of March 23, 1987, in which you enquired whether the bridging supplement received by XXXX is to be considered a retiring allowance or pension income. ...

However, we subsequently learned that the issue involved is presently being considered by Vancouver District Office personnel in connection with a tax return already filed. ...

A taxpayer does not need to request nor receive a formal ruling to be considered as a mutual fund trust under the Act, but he has to meet all conditions of subsection 132(6) of the Act. ...