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Paragraph 11 of IT-467 states, "The interest element, if any, in an award for damages is considered to be a component of the damages, Such interest included with damages awarded will be deductible if the damages themselves are deductible. ...

It would appear to us that upon a switch of the life insured, the change in circumstances is so substantial that a new policy is in essence considered to have been issued. ...

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. ...

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 is generally our view that a "group of persons" will not be considered to have acquired control of a corporation unless such persons have a common link or interest or act together to control the corporation. ...

Accordingly, it is conceivable that a corporation which derives its income from property or from gains from the disposition of property (other than inventory) could be considered to be engaged in a business, depending on the nature of its activities. ...

We understand that there are complex forward sale contracts which permit delivery deferrals at a penalty in the price for the production, but have not examined such contracts, and have, at this time, no firm view as to whether such contracts may be considered, in whole, or in part, as hedges. for Director Bilingual Services and Resource industries Division Ruling Directorate ...

In consequence, we agree that where a pension plan or a registered retirement savings plan invest 90% of its assets in a mutual fund trust, which would not be considered foreign property pursuant to the provisions of the Regulations described above, it may invest the full 10% of its remaining assets exclusively in foreign property without attracting tax under Part XI of the Act. ...

Thus, you feel that if the company had used the related funds to produce income from a business or property, the relevant comments in interpretation, bulletin IT-239R2 and paragraph 8 of IT-485 should be considered applicable such that the payments made by the director could represent an allowance business investment loss ("ABIL") of the director. ...

As the sole purpose of a training trust (as proposed by the Employment and Immigration Commission of Canada) is the training of the employees of an employer, the training trust would not be considered an employee benefit plan ("EBP") by virtue of paragraph (d) of the definition of the term EBP in subsection 248(1) of the Act. ...