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As you may have already gone to print with your form this change could be considered in the event the form is revised at a later date. ...

An opinion that we received from our legal advisers has confirmed that the status of an approved entity is subject to section 241 of the Act and is considered to be confidential income tax information relating to a particular taxpayer. ...

On the death of B, the actual transfer of the property to the registered charity will be considered as a distribution of property to a beneficiary in satisfaction of his capital interest and will be subject to the rules contained in section 107 of the Act. ...

In order for a particular entity to be considered an agent of the Crown in right of a province, the law creating the entity must expressly make it an agent of the Crown, or it must be an agent of the Crown at common law (see IT-297R). ...

IT-337R2 (copy enclosed), in part, outlines certain requirements to be satisfied in considering whether an arm's length payment would be considered to be a reasonable retiring allowance, and a deductible outlay to the payer. ...

In order for a particular entity to be considered an agent of the Crown in right of Canada or a province, the law creating the entity must expressly make it an agent of the Crown, or it must be an agent of the Crown at common law. ...

However, in our opinion, subscribed capital would generally not be considered to be part of paid-up capital. ...

We cannot confirm that the cash would be considered to be invested in or utilized by the operating company in the circumstances described inasmuch as the cash is not in fact invested in shares or debt of the connected operating company. ...

It is our opinion as stated in the 1981 Tax Conference that where a person or persons incorporate new companies and the incorporation of these companies is involved in the series of transactions or events that include the payment of dividends, their interest in the new corporation will be considered as an increase in the interest in any corporation. ...

We have verified with Registrations that the Plan in question, while it will be terminated, is still considered active for Revenue Canada purposes since the funds have not yet been distributed. ...