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An attendant would therefore be considered to be providing full-time care to an individual if the attendant devotes all their time to caring for the individual on a constant basis during the period for which the attendant is remunerated and that care is continuously required due to the individual's severe and prolonged physical or mental impairment. ...

The proportion of 70% of the salary earned by the Physician could be considered to be situated on the Reserve and would therefore be exempt from tax …. ...

Regarding the allocation of safe income of Pubco to the “new shares” acquired on exercise of the option, the Agency confirmed its position in the 1988 Read paper that where a person acquires an option to purchase shares of a corporation, for purposes of computing the safe income attributable to the new shares, the person is considered to have acquired the new shares at the time of acquisition of the option, so that some portion of any income earned by the corporation after its issuance of the option will accrue to the unexercised options rather than to the existing shares, and so that a gain inherent in the new shares may be referable to income earned by the corporation before the option was exercised. ...

13 April 2000 External T.I. 1999-0014465 F- UTILISATION DE PRODUITS D'ASSURANCE-VIE-- summary under Paragraph (d) Summary Under Tax Topics- Income Tax Act- Section 148- Subsection 148(9)- Disposition- Paragraph (d) addition of disability option clause to an insurance policy results in its disposition by operation of law if under the CCQ such change “results in the creation of a new contract” In the course of a general discussion, the Agency stated: In general, where a life insurance policy includes a combination of life and disability insurance and disability insurance is incidental to life insurance, the policy could be considered a life insurance policy. … Furthermore, if the disability option clause is added to the contract, it will be necessary to determine whether that amendment will result in a disposition of the life insurance policy. … [Under] the definition of “disposition” in subsection 148(9) … there could be a disposition of that interest by operation of law only … [as to which] it must be determined whether the change to the existing contract results in the creation of a new contract under the Civil Code of Quebec. … In addition, paragraph 148(10)(d) provides that a policyholder will be deemed not to have disposed of or acquired an interest in a life insurance policy as a result only of the exercise of any provision of the policy. ...

Regarding the expression, can reasonably be considered to be income derived from the provision of goods or services by a partnership or trust to or in support of a business carried on by the specified persons listed in s. 120.4(1) – split income- (c)(ii)(C), CRA stated. ...

Although it was not within CRA’s remit to determine which of these two should have received the adjustment, it would not object to the heiress being considered to have received the adjustment directly from the employer if she was entitled to the retroactive salary adjustment under the will. ...

In both cases, the hydrogen was considered a byproduct, representing 1% by mass of the products in the case of the chlor-alkali process and 5% by mass in the case of the chlorate process. ...

CRA was queried as to whether the Act permitted a choice as to the order in which the properties were disposed of, in order that a terminal loss could be realized as a result of the last property being considered to be disposed of to the unaffiliated person. ...

In the context of there having been an amalgamation, s. 87(2)(z.1) provided that if a capital dividend were paid by a predecessor corporation and a portion thereof would be deemed to be a taxable dividend by s. 83(2.1), the CDA of the predecessor corporation is not transferred to the amalgamated corporation – so that it would thus be necessary to determine whether all or substantially all of Corporation A's CDA, immediately before the payment of such a dividend, could reasonably be considered to consist of amounts not described in paras. ...

CRA noted that it would thus be necessary to determine whether all or substantially all of Corporation A's CDA, immediately before the payment of such a dividend, could reasonably be considered to consist of amounts not described in paras. ...