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The Department's position as set out in paragraph 2 of Interpretation Bulletin IT-131R2 is that a convention held during an ocean cruise is considered as being held outside the territorial scope of the organization. Since subsection 20(10) of the Income Tax Act requires the convention to be held at a location that can reasonably be regarded as consistent with the territorial scope of the organization it is our view that the expenses relating to a convention that your clients propose to hold during an ocean cruise (a cruise to Alaska is considered an ocean cruise) would not be deductible by the members. ...

Answer Section 74.4 requires that one of the main purposes of the transfer may reasonably be considered to be to reduce the income of the individual and to benefit a designated person, as defined in subsection 74.5(5) of the Act. ... The Department is of the opinion that the right conferred upon a designated person (as defined by subsection 74.5(5) of the Act) to share in dividends or capital appreciation of a corporation is considered to be a benefit for the purposes of subsection 74.4(2) of the Act. ...

Department's Position Provided the employee has an enforceable claim as at the date of death against the employer for the amount of the bonus declared, the value of that right at the date of death would be considered a "right or thing" within the meaning of subsection 70(2) of the Act. However, where the employer has a contractual obligation to pay a bonus annually or on some other periodic basis, but the bonus for the period has not been declared as of the date of death, the amount is considered to be a periodic payment of remuneration taxable under subsection 70(1) of the Act. ...

It is our opinion that XXXX has supplied sufficient evidence to prove he was not a sojourner and therefore would be considered a resident of Canada from the date he entered Canada for purposes of the Act. ... The term "resident" is not defined in the Act and section 250 is simply an "extended meaning of resident" which brings in certain individuals not otherwise considered residents of Canada. ...

We have an informal opinion from the Rulings Division that article XIV of the Canada/United Kingdom Income Tax Agreement does not apply in this case, as the XXXX would, in their view, not be considered to be "other similar remuneration". The question whether the payments would be of an income or a capital nature was not considered. ...

Ruling TR100 expresses our opinion on what is considered to be a reasonable retiring allowance in a non-arms length situation. ... An amount in excess of that considered reasonable would be included in the taxpayer's income by virtue of 6(3). ...

Ruling TR100 expresses our opinion on what is considered to be a reasonable retiring allowance in a non-arms length situation. ... An amount in excess of that considered reasonable would be included in the taxpayer's income by virtue of 6(3). ...

Interpretation Bulletin IT-106R "Crown Corporation Employees Abroad" (copy enclosed) outlines the factors to be considered in the determination of whether an employee of a crown corporation is an officer or servant of Her Majesty for the purpose of subsection 250(1) of the Income Tax Act. Employees of Canadian National Railways are generally not considered to be officers or servants of Her Majesty. ...

The first sentence of this paragraph should read "The alterations- of clothing at a retail clothing establishment on the sale of custom tailored or off the rack articles is considered to be a qualified manufacturing or processing activity". ... As it is the alterations of clothing at a retail clothing establishment that is considered to be a qualified manufacturing or processing activity it seems appropriate that a separate record of this type of income be maintained to determine if a deduction may be made pursuant to section 125.1 of the Income Tax Act. ...

Would short term deposits in which the flow-through share funds have been invested until they are required be considered assets which are used in an active business? ... Short term deposits in which flow-through share funds have been temporarily invested until they are required to be expended under the terms of the flow-through share agreement will be considered as assets which are used in an active business. ...