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Please feel free to make any submissions on this topic that you wish to have considered before we finalize our positions. ...

As subsection 26(5) of the ITAR is applicable, as explained below, it is our view that all the Y Co shares of C will be considered Group 3 shares and will be segregated (as indicated in subparagraph 6(a) of IT-199) as follows: a. ...

In any event, a request for an advance income tax ruling cannot be considered where the transactions are completed or where the issues involved are primarily questions of fact. ...

We also note that the tax paid by Canco would be considered to be paid in respect of income from a share of the capital stock of a foreign affiliate and is therefore not eligible for deduction from tax under subsection 126(1) of the Act or for a deduction in computing income under subsection 20(12) of the Act. ...

Duff 983367 Attention:XXXXXXXXXX March 1, 1999 Dear XXXXXXXXXX: Re: Farm Land as Qualified Farm Property This is in reply to your letter of December 11, 1998, requesting our views as to whether farm land, described in various situations, would be considered to be qualified farm property for the purposes of subsection 110.6(2) and whether it can be rolled pursuant to subsections 70(9) and 73(3) of the Income Tax Act. ...

A transfer for fair market value consideration is not considered to have taken place for purposes of the Act unless a number of conditions are met. ...

(footnote 7) Based on these judicial tests, it is probable that the production of biofuels and chemicals from municipal solid waste may generally be considered as manufacturing or processing. ...

Indeed, where a corporation confers a benefit on a person other than a shareholder, the courts have considered who caused the benefit to be conferred and the purpose for conferring the benefit. ...

While an RRSP might acquire a charitable annuity as an investment, the application of subsection 146(9) of the Act must also be considered. ...

Pursuant to subparagraph 6801(a)(iv) of the Regulations, the Plan must provide that any interest or additional amounts (capital gains) that may reasonably be considered to have accrued for the benefit of the employee in a year must be paid in that year to the employee. ...