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In order for the amount of a retiring allowance to be considered reasonable in a non-arms length situation, it should not exceed the amount that would be considered reasonable in an arm's length situation. ... Accordingly, in the above situation and assuming (i) is met, the daughter would be considered financially dependant on the mother and the proceeds from the mother's RRIF would be considered a refund of premiums to the daughter. ... A shareholder's loan which is repaid within one year of the end of the taxation year in which the debt was incurred may be included in income if it is considered to be part of a series of loans and repayments. ...

A would be considered to have acquired control of the corporation, resulting in a deemed year-end (taxation year 3) pursuant to subsection 249(4). ... In this regard, we also considered the provisions of subsection 256(7), which deems there not to be an acquisition of control in some situations, and determined that they did apply to any of your hypothetical transactions. ...

Assuming an election under subsection 98(3) of the Income Tax Act (the "Act") is not made, the following questions were asked: (a)at what point is each partner considered to have disposed of its partnership interest? (b)will each partner obtain the increase in the adjusted cost base of its partnership interest pursuant to subparagraph 53(1)(e)(viii) and subsection 66.4(6) of the Act before the partner is considered to have disposed of his partnership interest? ...

The amount of a reimbursement, among other things, received by a taxpayer in respect of the cost of property or in respect of other expenditure, if included in income under paragraph 12(1)(x) of the Act may be considered a non-government assistance payment. ... Where, under a contractual arrangement, NRCo does not carry on any business in Canada and reimburses CANCo in respect of SR & ED expenditures incurred by CANCo in Canada and CANCo includes the amount of the reimbursement in computing its income from a business carried on in Canada pursuant to subsection 9(1) of the Act, it is our position that the reimbursement would not be considered to be a non-government assistance or a contract payment for the purposes of paragraph 127(11.1)(c) of the Act. ...

According to subsection 13(27), the vessel will be considered to be available for use at the earliest of: (a) the time at which the property is first used by the taxpayer to earn income (which is 1993 in the case at hand),... ... What is at issue, though, is whether the vessel is considered to be acquired "after Dec. 2, 1992 and before 1994". ...

Response to your first question The at-risk rules are relevant for a partner in a general partnership when he is considered a limited partner by virtue of one or more of the paragraphs (a) to (d) of subsection 96(2.4) of the Act. ... Consequently, a general partner of such a partnership will not be considered to be a limited partner by virtue of paragraph 96(2.4)(b) of the Act only by reason of the non- recourse or limited recourse loan. ...

According to subsection 13(27), the vessel will be considered to be available for use at the earliest of: (a) the time at which the property is first used by the taxpayer to earn income (which is 1993 in the case at hand), (g) where the property is acquired by a fisherman to be used in fishing, the time at which the property has been delivered and is capable of performing the function for which it was acquired (which is 1992 in the case at hand), and (h) where the property is a vessel for which one or more permits, certificates or licences are required to be obtained, the time at which all such permits, certificates or licences have been obtained (your question did not state any relevant facts). Where the vessel requires a permit, certificate or licence in order to be operated legally, it is our view that the vessel could not be considered to be capable of performing the function for which it was acquired until such permit, certificate or licence is obtained. ...

Such income and benefits are considered to be property of an Indian on a reserve. In order to reach that decision the Court had to conclude that the situs of the debtor (being on a reserve) is not the sole factor to be considered in exempting income from taxation since unemployment insurance benefits are not paid from a reserve. ...

., a water well to be used in the operation of that business, such costs would likely be considered as being related to that farming business to the extent that the well is so utilized. As discussed in paragraphs 2 and 3 of Interpretation Bulletin IT-206R, where a taxpayer simultaneously carries on two or more business operations, such activities may be considered to constitute the same business for purposes of the Act. ...

Is the rollover from a U.S. employer pension plan to the IRA considered income for purposes of paragraph 3(a) of the Act such that it would cause a tax liability under Part I.2, even though the rollover is deductible under subparagraph 110(1)(f)(i)? ... Answer: An interest in an IRA is considered a "right or thing" within the meaning of subsection 70(2) of the Act and in the year of death there are three alternative tax treatments available as follows: 1) the total value may be included in the deceased's income in the year of death and, if exempt from income tax in the United States, a corresponding deduction taken under subparagraph 110(1)(f)(i) of the Act, 2) the deceased's legal representative may make the election under subsection 70(2) of the Act and file a separate return, including the value of the IRA in the income reported on the separate return and, if exempt from income tax in the United States, claiming a corresponding deduction under subparagraph 110(1)(f)(i) of the Act, or 3) amounts received out of the IRA may be taxed in the recipient beneficiary's hands under clause 56(1)(a)(i)(c.1) of the Act in the year of receipt if ownership of the IRA is transferred to the beneficiary (whether the spouse or child) in the time specified in subsection 70(3) of the Act. ...