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We have not considered, and were not providing comments with respect to the application of paragraph 138.1(1)(j) of the Act in circumstances where the guarantee amount exceeds the net contributions under the policy or where the guarantees are payable on a more frequent or periodic basis. ...

You may have specific situations that need to be considered as exceptional cases. ...

With respect to the last question, we are of the opinion that, in general, the interest income attributed to a corporation pursuant to paragraph 107.3(1)(a) of the ITA could be considered as income pertaining to or incident to its business for the purposes of computing the "income of the corporation for the year from an active business" within the meaning of the definition provided in subsection 125(7) of the ITA. ...

Hence, the rights resulting from a call option agreement must be considered when determining whether a share constitutes a QSBCS for the purpose of subsection 110.6(1) of the ITA. ...

Is a beneficiary considered to have income earned in the estate payable to him or her by virtue of their residual entitlement to the estate? ...

With regard to this particular arrangement, several issues need to be considered to determine the tax consequences to the investor. ...

CRA Response The CRA has recently considered arrangements to fund benefits that are to be provided to employees under the provisions of plans that are identified as unregistered pension or supplementary pension plans. ...

However, an amendment to paragraph (e) of the definition of "benefit" in Regulation 1408(1) would be considered only where appropriate and only where the terms of the contingent benefits as expressed in the annuity contract are sufficiently similar to those specifically set out in the indexed-linked GIC as set out in RID documents 2001-0076265, 2001-0079875, 9406155. ...

One of the requirements for such an investment to be considered a qualified investment under subsection 4900(12) of the Income Tax Regulations ("ITR") is that the share acquired by the RRSP must be a share in a small business corporation (SBC) at the time of its acquisition. ...

The situations considered at those conferences involved the distribution of property by a Canadian resident discretionary family trust to a Canadian corporation whose shares would be wholly owned by a newly established Canadian resident discretionary family trust. ...