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Any amendments to the legislation would have to be considered by the Department of Finance. ...

As a result, if a true joint tenancy arrangement were created, you would be considered to have disposed of a SO-per-cent interest in your shares to your daughter at fair market value on the date of the transfer, and you would be required to report the disposition on your tax return. ...

Although the Income Tax Act does not specifically define what constitutes a capital expenditure or a repair, the courts have identified certain factors which should be considered in making such a determination. ...

A trust is considered to be an individual. Five months after the end of the partnership’s fiscal period if, throughout the fiscal period, all partners are corporations, including end members of a tiered partnership. ...

Some of the items that would have to be considered are the purpose of the transaction, whether the trust agreements permit the proposed merger, etc.  ...

A would be considered to be, in and by itself, a completed transaction in "settlement of rights arising out of their marriage" for purposes of paragraph 73(1)(b) of the Act.  ...

Hypothetical Situation We have considered the matters raised by you in the context of the following hypothetical fact situation: 1.      ...

The insurance company has requested confirmation (1)     that the additional premium paid by an employer in respect of the special disability benefit would not be considered a taxable benefit to the employees by virtue of the exclusion in subparagraph 6(1)(a)(i) which refers to payments in respect of group sickness or accident insurance, and (2)     that the special disability benefit payable to an employee who becomes incapacitated by certain illnesses (i.e. heart attack, stroke, paraplegia or cancer) would not be taxable under paragraph 6(1)(f) since (a)      the amount is not paid on a periodic basis, and (b)      the amount payable in calculated as a percentage of the group life insurance coverage and is not referable in any manner to a loss of employment income. 21(1)(b) We would appreciate receiving your views, in tax policy terms, of the above-noted matters. ...

We understand the share structure of 24(1) is as follows: 24(1) Other relevant facts are as follows: 24(1) Our Views We confirm our earlier opinion, expressed in our letter dated February 11, 1986 to 19(1) that where the 90% share ownership test is met by the corporation has the right to redeem its preferred shares, it could, for purposes of subparagraph 149(1)(d) of the Act, be considered that "a person other than Her Majesty in right of Canada or a Province of a Canadian municipality had during the period, a right under a contract, in equity or otherwise either immediately or in the future an either absolutely or contingently, to or to acquire, shares or capital of that corporation".  ...

Accordingly, it is our view that the arrangement proposed by your company as outlined above would not be considered to be an employee-pay-all plan and would, therefore, not maintain its non-taxable status with respect to any benefits paid out of the plan to your company's employees. ...