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For example, where deductions in respect of Canada Pension Plan contributions and Unemployment Insurance have been withheld from the payments made in 1988 and 1989 (the fact that the employer or administrator withholds source deductions may be indicative that the monies were not considered a loan or advance) when in fact the monies were a non-taxable advance not subject to source deductions, then it is our view that the taxpayer's 1988 and 1989 T4 returns may need to be amended such that insurable earnings and pensionable earnings of the employee are accurately reflected. ...

Such arrangements are considered to be an annuity contract for purposes of the Act and the annuity payments are included in computing the annuitants income under paragraph 56(1)(d). ...

To be considered a retiring allowance, in other words, the payment from an employer must be made after or in respect of the severance of the employment relationship. ...

If it is the latter, it is your view that the non-capital loss incurred from a business carried on in Canada by the individual while he was a resident of Canada could not be considered to be applicable to a business carried on by that person in Canada any income from which would have been required by subsection 115(1) of the Act to be included in computing his taxable income earned in Canada. ...

Even it they were considered to be money purchase benefits they could still be transferred pursuant to subsection 147.3(1). ...

Where paragraph 6(3)(b) does not apply, the amounts are considered to be "superannuation or pension benefits" whether they are paid out of the former employer's pension funds or from general funds and as such are subject to tax in the hands of the pensioner pursuant to paragraph 56(1)(a). ...

Will an amount of pension income receivable by an estate that is paid pursuant to a court order into the court for the benefit of the deceased's minor children be considered an amount that became payable in the year by the estate under paragraph 104(6)(b) and subsection 104(24)? ...

If this is in fact the case, we are of the view that the PPS would be considered a personal retirement arrangement and, as stated in our earlier memorandum, there is no provision in the Act that would allow for a tax-deductible transfer of the funds held in the PPS to an RRSP. ...

If grandfathered, this plan would be considered an employee benefit plan ("EBP"). ...

Where a registered charity solicits funds for a general charitable purpose and the donor expresses a desire that the gift be applied by the registered charity in a particular fashion, provided that the desired application is squarely within the purview of the responsibilities and functions normally carried out by the registered charity, in our opinion, such a donation would be considered a gift for purposes of the Act. ...