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You would like to know whether spouses who are living separate and apart by reason of a breakdown of their marriage would be considered related persons for the purposes of paragraph 251(2)(a) of the Act. ...

For all purposes the distinction between principal and interest on the obligation from the perspective of the issuer is ignored, and it is as if all of the payments by the issuer are considered to be a series of zero coupon obligations. ...

In other words, if any of the assets of the employer have been set apart from the assets that are available to the employer to fund operations or satisfy creditors, a contribution to an RCA can be considered to have occurred. ...

Where the principal reason for the allocation may reasonably be considered to be a reduction or postponement of tax that might otherwise have become payable under the Act, the Department would seek to apply the provisions of section 103. ...

Accordingly, if a particular Mandate gave a mandatary control of the voting rights of an Individual's shares on the happening of an event which would not be considered a permanent disability (or death or bankruptcy), within the meaning of subsection 256(1.4), it is our view that the afore-mentioned exception would not apply and the mandatary would be deemed to own those shares. ...

In the case of salary and employment-related benefits, the amounts are not considered received "for the benefit of" the child. ...

It is possible to allocate or credit an amount of nil to either all of the members or all of the customers who are not members and still have such amount considered to be an “allocation in proportion to patronage” within the meaning of paragraph 135(4)(a) of the Act. ...

Where a stock is traded actively on a public stock exchange, the fair market value of the stock is generally considered to be the average trading price on the day on which the payment is made. ...

On the other hand, if the amount is considered as a partial reimbursement of rent expense, the amount is included in income under paragraph 6(1)(a) of the Act as a benefit of any kind received in respect of an office or employment. ...

Similarly, it is your view that the real property owned by the individuals in the second scenario should also not be considered to be non-qualifying real property. ...