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We should point out that the Department of Finance considered it necessary to enact paragraph 18(1)(n) to specifically not allow the deduction of political donations in the computation of the income from a business or property. ...

In making this determination, all of the relevant facts in each case must be considered." ...

In Interpretation Bulletin IT-496, Non-Profit Organizations, the Department has outlined some of the factors that are considered relevant in determining the exempt status of an entity under 149(1)(1) and under what circumstances such an entity would lose its exempt status. ...

A government's funding of programs out of tax revenues that may have income tax consequences for the recipients thereof is not considered to be double taxation. ...

As indicated in paragraph 5 of that same circular, the utilization of tax losses within a related corporate group is, in and by itself, generally not considered to be a misuse or abuse of the Act. ...

Furthermore, we do not agree with your statement that, as the trust is considered as a non-resident corporation for purposes of the foreign accrual property income ("FAPI") calculation in clause 94(1)(c)(i)(B) of the Act, subsection 104(4) of the Act cannot apply since this subsection applies only to trusts. ...

However, given that it is a disposition of a debt, the provisions of paragraph 40(2)(g) of the Act would have to be considered to determine whether the loss would be deemed to be nil. ...

Section 3 of Article XVIII of the Convention defines "pension" to include any payment under a retirement plan, and a RRIF is considered a retirement plan. ...

Payette (613) 957-8953 Attention: 19(1) July 13, 1992 Dear Sirs; Re: Private Health Services Plan ("PHSP") This is in reply to your letter of May 5, 1992, wherein you requested confirmation that a payment/reimbursement by an employer qualifies as a PHSP pursuant to subsection 248(1) of the Income Tax Act (the "Act") and that the payment/reimbursement is not included in the income of the employees due to the exemption in subparagraph 6(1)(a)(i) of the Act and is considered expenses of the employer for purposes of paragraph 18(1)(a) in the following arrangement. 1. ...

An individual will be considered a resident of Canada when he is either a factual or deemed resident of Canada. ...