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You have also enquired as to whether or not the wholly-owned subsidiary would be considered to be a "customer" within the meaning of that term in subsection 135(4) of the Act. ...

Tremblay, CMA 957-2139 Attention: Sharon Bulger 2001-008275 XXXXXXXXXX This is in response to your memorandum of April 27, 2001, requesting our opinion on whether the premiums paid under a XXXXXXXXXX (the "Plan") can be considered medical expenses pursuant to paragraph 118.2(2)(q) of the Income Tax Act (the "Act"). ...

As you are aware, it is our position that the amount of the imputation tax credit attached to a franked dividend is not a tax paid by the Canadian resident taxpayer to the Australian government for the purposes of computing the taxpayer's foreign tax credit that may otherwise be available on such foreign source income under subsection 126(1) of the Act nor can such an amount reasonably be considered to have been withheld and remitted by the Australian corporation on account of the recipient's Australian tax liability. ...

It is our view that an employee who uses professional development funds provided by his or her employer in order to purchase a personal computer will be considered to have received a taxable employment benefit where the employee owns the computer. ...

Reasons: Part XII.6 tax would be considered to be an expense described in paragraph 1204(1.1)(a). ...

More specifically, you request whether the cost to an individual of child care services provided during a period where the individual is on strike may be considered child care expenses for the purposes of subsection 63(3) of the Act. ...

In so doing, we believe that the Court considered that an amount equivalent to the Annuity represented the actual cost of the Child's "food, shelter, education" and other personal expenses. ...

With respect to construction holdbacks payable and receivable, we acknowledge that they do not constitute reserves or other surpluses for accounting purposes, but we believe they may be considered provisions within the definition of "reserves" in subsection 181(1). ...

The vendor is not considered to have made any payment in respect of the contingent liabilities;? ...

Although part of Canco's work may be considered SR&ED, the CTM preparation has been determined not to be SR&ED under the definition of this term in subsection 248(1) of the Act. ...