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Peters (613) 995-0051 July 29, 1986 Dear Sirs: RE: Retiring Allowances This is in reply to your letter of June 19, 1986 requesting our views as to whether certain payments would be considered retiring allowances and therefore eligible for a rollover into the individual's RRSP subject to the constraints contained in subsection 60(j.l) of the Income Tax Act (the "Act"). ...

Such amounts would be considered to be "similar obligations" within the meaning of that term as contained in clause 212(l)(b)(ii)(C) of the Act. ...

A beneficiary of an RRSP is not considered to have paid the tax withheld on the foreign source income earned by the RRSP. ...

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. ...

Accordingly, expenses (legal, accounting and underwriting costs) incurred by a company on the issue of its warrants cannot be considered an expense which is inherent or essential to the issue of shares. ...

Specifically you have requested our opinion as to whether Eurobonds would be considered foreign property for the purposes of the 10% limitation contained in subsection 206(2) of the Income Tax Act ("Act"). ...

Since the payments under the Self Managed Care Project are made "on a means, needs or income test" they are considered to be social assistance payments for purposes of paragraph 56(1)(u) and subparagraph llO(l)(f)(iii) of the Income Tax Act. ...

As the legal fees were not incurred in respect of a business and also were not incurred for the purpose of gaining or producing income from a business they would not be considered "eligible capital expenditures". ...

Will the beneficiary be considered to have a substantial interest, within the meaning of subsection 191(2), in the corporation? ... The amount, if any, that is considered to be reasonable will be based on the facts of each particular case. ... 2) What deductions will be considered favourably? 3) Is there a threshold amount below which a reduction will not be considered? ...

Revenue Canada has considered that such a purpose is present if an outlay is made with an expectation of profit. ... Subsection 245(2) of the Act was considered applicable to require an inclusion in income of the cash held by a distributor. ... Unusual items such as deferred charges should be considered as a possible way of circumventing the 95% debt limit. ...