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The opinions expressed herein are not advance income tax rulings and in accordance with paragraph 21 of Information Circular 70-6R2 dated September 28, 1990 are not considered binding on the Department. for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch9104000- 9104999 ...

In our view, plans that permit the carry forward of unused amounts in the plan to the following year and the carry forward of unused medical expenses would not be considered to have a reasonable element of insurance. ...

Generally, a return of contributions to an employee would be considered a lump sum payment.  ...

With respect to the questions posed in 1, above, the Department takes the view that, unless the note is accepted as absolute payment as discussed in paragraph 2(b) of IT-436R an ordinary promissory note is considered to be a promise to pay and not payment of the remuneration owing.  ...

Educational leave or an educational grant paid by an employer to an employee is considered to be received in respect of, in the course or, or by virtue of the employee's office or employment and is included in income from an office or employment by virtue of paragraph 6(l)(a) of the Income Tax Act. ...

On the assumption that the value of the consideration for the use of the cars supplied by the manufacturer is the annual cost of leasing a similar vehicles by A Co, that value would be considered as "amounts that may be reasonably regarded as having been payable by the employer to a lessor... ...

The description should contain statements which clearly demonstrate that the organization will satisfy all requirements of the relevant provisions of the Act (such as those stated in the post-amble of subparagraph 37(1)(a)(ii), which are requirements which funders must meet in order for their payments to be considered as SR&ED expenditures) and should describe how property will be distributed in the event of windup; (c)     a description of the entity's arrangements for funding; (d)     a description of the entity's arrangements for disbursing moneys; and (e)     a description of the entity's staffing and planned activities. ...

We agree with your conclusion that "the amount that can reasonably be considered to be the amount he would have deducted" would be net of the capital gains exemption claimed for regular tax purposes. ...

It is our opinion that options to acquire real property, where such options constitute inventory to the holder, would be considered to be "eligible property" within the meaning of subsection 85(1.1) by virtue of paragraph (f) thereof. ...

The amendment had the effect of including in income (applying a specific formula) payments in respect of damages for wrongful dismissal that were not otherwise considered to be a retiring allowance. ...