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It is our view that the following factors would have to be considered in determining whether an insurer has transferred all or substantially all of an insurance business or a line of business: 1.      ...

The facts as summarized in your memorandum are as follows: 1)      24(1) 2)     The Department in a letter dated March 26, 1980 to  24(1) 24(1) states, "The Department will continue to recognize that "the spouse" be considered entitled to receive the refund from a RRSP despite the fact such funds may be payable to the estate.  ...

The existence of Social memberships might be considered to be running a business, however, as discussed above, the Act contemplates that an organization may carry on income generating activities and earn income and still qualify for exempt status.  ...

Cette position peut se résumer de la façon suivante relativement aux dépenses de nature courante:      «(b) Current Expenditure:       An amount paid in the ordinary course of a property rental business to a non-anchor tenant is considered to be on income account.  ...

., October 25, 1990, under appeal, McNair, J. considered whether certain deductions in computing income were required to be deducted in computing taxable production profits from a mineral resource in Canada under subsection 124.1(1) of the Act (now repealed).  ...

Factors to be considered in applying this test include the required investments to be made by the individual, permanency of the relationship, and the skill required by the individual (d)     SPECIFIED RESULTS TEST This test acknowledges that an independent contractor relationship usually involves the undertaking of a specific task after which the relationship ceases. ...

You also asked whether the for an RRSP contribution than for other "purchase" transactions could be considered an "advantage" within the meaning of paragraph 146(2)(c.4) of the Income Tax Act (the "Act"). ...

Briefly, the primary concern is that the corporation maintains that it is carrying on an insurance business and is, accordingly, entitled to a reserve for unearned premiums pursuant to paragraph 20(7)(c) of the Income Tax Act (the "Act") as calculated according to section 1400 of the Income Tax Act Regulations (the "Regulations"). 24(1) 24(1) While we do not have any expertise as to what would constitute a "reasonable commission" we agree with Stan Trevor that this must be considered given that we are dealing a with a non-arm's length arrangement. ...

Secondly, it seems to us that, if the deduction might be considered logically to offset any income amount, that amount would be the income inclusion under paragraph 12(1)(e) with respect to the reserve under paragraph 20(1)(m) claimed for the preceding year. ...

For example, partnership income allocated to the original partner under the terms of the partnership agreement and owing to the partner after disposition of its interest may be considered a residual interest.  ...