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Since the payments are required to be made by virtue of section 227.1 of the Act and the debts can not be considered to have been acquired by the director for the purpose of gaining income from a business or property the director's loss respecting the debts would be nil by virtue of paragraph 40(2)(g) of the Act. ...

However, we agree with the opinion given to the joint committee that for purposes of 110.6 a partner will be considered to have disposed of property where the partnership in fact disposes of the property. ...

It should be noted that where an employer acquires an interest in a life insurance policy that may reasonably be considered to fund benefits to be received by an employee upon his retirement or upon substantial change in services rendered, the arrangement would be subject to the retirement compensation arrangement rules by virtue of subsection 207.6(2) of the Act. ...

The sentence would then read as follows:      "For example, a single unit within the building (which would be a class 6 building if it were not a condominium) is itself considered to be a class 6 building. ...

DEPARTMENT'S POSITION Where an election under subsection 97(2) is made indicating that particular property is capital property, but upon subsequent review by Revenue Canada it is determined to be inventory the election filed will not, for this reason, be considered invalid.  ...

Furthermore, investment income and proceeds of disposition of such investments are not considered to be foreign property provided they are immediately converted to Canadian currency or promptly used to acquire property that is not foreign property. ...

In the context of a corporate partnership, due to the fact that under the common law all members of a partnership carry on the partnership business whether or not they are actively engaged in the activities of the partnership business, each corporate partner is considered to carry on the business of the partnership irrespective of whether or not the partner controls the partnership.  ...

The issue of issue to publish ann Interpretation Bulletin has been considered by the Publications Division and it is their view that there would be an insufficient number of taxpayers who would benefit therefrom to justify the cost. ...

IT-337R2 (copy enclosed), in part, outlines certain requirements to be satisfied in considering whether an arm's length payment would be considered to be a reasonable retiring allowance, and a deductible outlay to the payer.  ...

As indicated in item 3 of our March 14, 1989 letter, interest earned on a participating employee's deferred salary under the Plan for a year is considered to be employment income for that year. ...