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Has Revenue Canada considered establishing a program to permit established private health services plans that are in technical violation of Revenue Canada's administrative requirements to return to full compliance with all of the rules? ...

" Even though the divorce agreement indicates a contradictory intention of the parties to both split the pension income and for the amount paid out of the pension to the Wife to be considered support to the Wife and thus deductible to the Husband, we believe the better view is that the Husband has assigned to the Wife one-half of his gross pension accumulated during the years of married cohabitation, resulting in Husband and Wife each having pension income included in income pursuant to subparagraph 56(1)(a)(i) of the Income Tax Act equal to the amount distributed to each from the pension plan. ...

Split income includes income received from a trust which can reasonably be considered to (A) be in respect of taxable dividends received in respect of shares of the capital stock of a corporation (other than shares of a class listed on a prescribed stock exchange or shares of the capital stock of a mutual fund corporation), (B) arise because of the application of section 15 in respect of the ownership by any person of shares of the capital stock of a corporation (other than shares of a class listed on a prescribed stock exchange), or (C) 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 (I) a person who is related to the child at any time in the year, (II) a corporation of which a person who is related to the child is a specified shareholder at any time in the year, or (III) a professional corporation of which a person related to the child is a shareholder at any time in the year. ...

Would payments under this assignment be considered taxable pension income of the taxpayer pursuant to paragraph 56(1)(a) of the Act and subject to source deductions pursuant to subsection 153(1) of the Act? ...

However, for your information we have the following general comments as to some issues that we believe are raised by the proposed structure that would have to be considered before giving any such confirmation should an advance tax ruling be requested. ...

Reasons: (i) For the purposes of paragraph 6(1)(b) of the Income Tax Act (the "Act") the allowance is considered to be for "personal or living expenses or as an allowance for any other purpose. ...

The Department did not appeal this decision, and it is only to be considered as a precedent in the same situation. ...

Generally, acquisition will be considered to have taken place when title passes or, if title remains with the vendor as security for the unpaid balance, when all the incidents of title (such as possession, use, and risk) pass (see current version of IT-170, Sale of Property- When Included in Income Computation). ...

The trust notes held by the SBILP constitute an asset to it and therefore could not possibly be considered to be "borrowed money", which would be a liability of the SBILP (a "promise to re-pay"). ...

Since you have asked us to only consider the Class 14 issue, we have not considered the submission of XXXXXXXXXX that concerns XXXXXXXXXX. ...