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Thus, where a corporation carries on a business in a taxation year the principal purpose of which is to derive income from property and neither of the aforementioned conditions are met, it is our view that the corporation would be considered a specified investment business. ...

The courts have generally considered that control means de jure control as opposed to de facto control. ...

We cannot answer your question since the matter of whether or not a taxpayer is merely investing funds or is carrying on a business of investing funds is a question of fact and each case would need to be considered on an individual basis. ...

Such deferred salary leave plans that comply with Regulation 6801 of the Act are considered to be employee benefit plans. ...

Normally all are considered to be farming and any reference to these situations in the feedlot IT is in our view unnecessary. ...

Szeszycki (613) 957-2130 RE: Medical Expenses This is in response to your memorandum of March 21, 1988 requesting our opinion on whether necessary travel costs associated with bringing an individual to a location at which a donation of blood platelets can be made would be considered a deductible medical expense where those costs are borne by the recipient taxpayer. ...

" The issue raised in this case does not appear to have been previously considered by either the Department or the courts. ...

Consequently, it is our view that this amount is employment income pursuant to subsection 5(1) and/or 6(3) of the Act and that the amount cannot be considered a retiring allowance. ...

XXXX You have requested our opinion as to whether the costs incurred by the participants in attending these seminars will be considered to be deductible from income for tax purposes if the participants do not remain in Florida after the cessation of the seminars. ...

Would you please prepare a remission report in accordance with the guidelines set out in TOM 2263.24 and provide us with any relevant information or correspondence which may assist us in our review, together with your recommendation as to whether remission should be favourably considered. ...