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However, where the limited partner has a significant interest in the partnership we would expect his interest to represent the types of property held by the partnership (e.g. cash and near cash, investment and business property): The opinions expressed herein are not rulings and are not considered binding on the Department as outlined in paragraph 21 of Information Circular 70-6R2. ...

RESPONSE In our opinion, the conversion from a joint-tenancy arrangement to a tenancy- in-common, whereby on death each brother will have his interest pass to his estate rather than to the survivor of the two, will not be considered a disposition provided that, immediately after the conversion, each co-tenant retains his 50 percent  undivided interest in the property. ...

Kotlar Director File No. 5-8624 Subject: Independent Trustee for DPSP Enclosed, for your use, is a copy of the August 30, 1989 letter from 19(1) Since 19(1) seeks confirmation that a director may be considered as the trustee of a DPSP in circumstances that do not seem to fit your administrative rule outlined in paragraph 18(a) of Information Circular 77-IR3 we request that you review such circumstances and respond to her directly. ...

Whether Location A would be considered a remote place is a question of fact. We have not previously defined "remote" for purposes of IT-470R (Consolidated) and each location would have to be considered on a case by case basis. ... While a guideline based on distance would be appropriate in most cases, there may be situations where other relevant factors should also be considered in making such a determination. ...

There are distinctions among the 5 treaties that provide for this exemption and accordingly each must be considered individually. ... Treaty that was considered by the Supreme Court of Canada in H.N.R. v. ... (ii)     Norway and Trinidad & Tobago Treaties      These treaties are very like the old Treaty considered by the Tax Appeal Board in Dorian Smith v. ...

In addition, 1971 census division 19 which at that time was in southern Manitoba would be considered a prescribed area.  This is the only indication in subsection 4602(1) of the Regulations that favour one census year over the other and as such it should be considered as significant when determining whether the 1971 or the 1976 census divisions are to be used. 5)     21(1)(b) 6)     The fact that subparagraphs 4602(1)(h) & (i) of the Regulations refer to census divisions of Northern Saskatchewan and Peace River while the 1971 and 1976 census maps refer only to the division numbers does not appear to be relevant  23 Paragraph 18 of I.C. 78-4R3 identifies these two census divisions by number so as to assist any taxpayer who could not identify them by the names given in the Regulations. 7)     The reason that paragraph 18 of I.C. 78-4R3 identifies the British Columbia census division of Peace River- Liard as being census division number 55 rather than number 23 as in the 1971 census is because the number was changed to 55 for the 1976 census and the 1976 census was used in drafting I.C. 78-4R3.  ... Taxpayers located in census division 19 only during the 1971 census will not be considered to be located in a prescribed area. 2)     The prescribed area for Saskatchewan is census division 18 as contained in the 1976 census, also referred to as the census division of Northern Saskatchewan. 3)     The prescribed area for Alberta is census division 15, other than the area within the limits of the city of Grande Prairie, as contained in the 1976 census, also referred to as the census division of Peace River. 4)     The prescribed area for British Columbia is census division 55 as contained in the 1976 census, also referred to as the census division of Peace River- Liard. ...

A disability, as defined by the World Health Organization, is "any restriction or lack of ability to perform an activity in the manner or within the range considered normal for a human being".  ... The determination of whether a particular disability can be characterized as "permanent", for purposes of paragraph 256(1.4) (a) and (b) is a question of fact and accordingly, each case must be considered individually.  ... Paragraph 118.4(1)(a) provides, inter alia, that for purposes of this disability tax credit, "a person shall be considered to have a severe and prolonged impairment only if by reason thereof he is markedly restricted in his activities of daily living and the impairment has lasted or can reasonably be expected to last for a continuous period of at least 12 months. ...

Properties of a group are considered identical if each property in the group is the same as all the others. ...

Any proposal to change legislation must be considered by the Minister of Finance and approved by Parliament. ...

The bulletin explains that a plan will be considered a private health services plan only if it limits coverage to hospital care, hospital expenses, medical care, or medical expenses that normally qualify as medical expenses under the Act. ...