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However, after careful consideration of the circumstances, it is regretted that a recommendation cannot be made for the remission of the unpaid taxes and interest described in your letter of July 5, 1989 to The Honourable Harvie Andre. 24(1) While the situation may be considered to be unfortunate, I have not found any indication that the assessments arose for reasons that would not apply to other taxpayers in similar circumstances or that any unfairness was involved with regard to the application of the law. ...

You enquire as to whether the Second mortgage would be considered a qualified investment for the RRSP under subsection 146(1)(g) of the Act in the following cases: 1) assuming that the mortgagor deals at arm's length with the corporation and its shareholder; 2) assuming that the mortgagor does not deal at arm's length with the corporation or its shareholder. ...

We would further note that, with respect to both of the above referenced types of assets, property which is acquired and held in the ordinary course of a particular business is considered to be "used in Canada" for purposes of the calculation. ...

Consequently, Corporation A would be considered a qualifying corporation in 1989 as its taxable income and that of its associated companies in the preceding year did not exceed the business limit. ...

Spice (613) 957-8953 24(1) Attention: 19(1) September 3, 1992 Dear Sirs: Re: Definition of "Eligible Corporation" in Subsection 5100(1) of the Income Tax Act Regulations (the "Regulations") This is in reply to your letter of July 23, 1992, in which you ask whether the underlying partnership interest of a taxable Canadian corporation could be considered when determining whether such a corporation is using substantially all of its property in carrying on a "qualifying active business" (as defined in subsection 5100(1) of the Regulations). ...

Accordingly, it is our view that the above noted health professionals would not be considered as medical practitioners under the Income Tax Act with the exception of acupuncturists practising in the province of Quebec. ...

Rather, Revenue Canada's authority in this regard would normally be limited to challenging the value assigned to the property by the RRIF trustee and annuitant where the value so assigned is considered to be unreasonable in the circumstances. ...

" Accordingly, we cannot confirm your view that where the transaction is considered to be a sale rather than a lease the accounting treatment will determine the income tax treatment. ...

Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information Of necessity, the application of such an avoidance provision must be considered on a case by case basis with consideration of the facts of each particular circumstance. ...

The longer an individual remains at the old residence, the less likely it is that a subsequent move can be considered to be the direct result of the change in work location. ...