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Given the fact that a fishing licence cannot be issued to a corporation and that the terms of the fishing licences do not permit anyone other than the licence-holder to fish under that licence, should the income earned from fishing be considered to be the individual's income rather than the corporation's? ...

To the best of your knowledge and the knowledge of the Employer, none of the issues involved in this ruling request is being considered by a tax services office or taxation centre in connection with an income tax return already filed, and none of the issues is under objection or appeal. ...

In our view, the training assistance received by the individuals described above, under Part II of the EI Act or under the CRF will normally be considered allowances or benefits for the purposes of section 118.6 of the Act and the recipients would not be eligible for the education tax credit. ...

In our view, at the time of this novation, the Partnership would be considered to have made a payment or credit in kind of the Accrued Interest to the Creditor Affiliate by delivering the Debtor Affiliate’s covenant to make the payments under the Loan agreement to the Creditor Affiliate. ...

However, based on the information provided to us, it seems unlikely that any portion of the $XXXXXXXXXX loan to the XXXXXXXXXX could be considered to be a loan granted by virtue of their employment with the corporation. ...

(The wording of subsection 8507(3) of the Regulations lends support to this interpretation since it was considered necessary to deem allocations of surplus and forfeitures to be "contribution(s) made on behalf" of the member for purposes of paragraph (a) of that provision.) ...

The question whether a partnership existed was considered in Boles v. ...

The problem in this regard relates to unsettled jurisprudence on this point and the requirement that there be a "day-to-day accrual" for an amount to be considered interest. 2.Are there specific paragraphs in the original bulletin which have been identified as no longer reflecting the policy of the Department and what are those specific paragraphs? ...

As a result, her legal counsel feels that the Crown in right of Ontario must be considered to be present throughout Ontario, including reserves, and that, for purposes of the Indian Act exemption, an argument can be made that the debtor, the Provincial Crown, is located on a reserve. ...

As discussed in more detail below, after having considered the arguments provided in the Submission, our conclusions remain as expressed in the Opinion. ...