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It is apparent that forensic accounting is a specific type of accounting and that this type of work would therefore generally be considered to be part of an accountant's professional practice. ...

Our Comments As stated in its response to question 14 at the 1985 Revenue Canada Roundtable, the Department has always considered that a benefit would be conferred on a corporation's shareholders in any situation where property is held by the particular corporation for the personal use of its shareholders. ...

Day (613) 957-2136 October 6, 1992 Dear 19(1) Re: Interpretation Bulletin IT- 339R2- Meaning of Spouse We are writing in reply to your letter of August 11, 1992, wherein you requested our views as to whether or not a same-sex spouse could be considered to be a "spouse" and thus an eligible dependent under the terms of a company sponsored private health services plan ("PHSP"). ...

Our Position We have not considered the issue whether, as a matter of corporate law, it would be possible to attach rights or attributes to a preference share that are different from those attached to another preference share of the same class. ...

The Department would become involved only after the fact and only if it considered the value assigned to a property to be unreasonable in the circumstances. ...

If a plan meets the criteria in Regulation 6801 it is considered not to be an SDA and, consequently, the deferred amounts will not be included in income until they are received. ...

Of course, 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. ...

Our Comments Whether or not a reimbursement described above is subject to tax depends on whether a recipient POH is considered to have received a benefit "in respect of, in the course of, or by virtue of" his or her office or employment for the purposes of paragraph 6(1)(a) of the Income Tax Act. ...

If all of the requirements listed in 2 above were satisfied at the time of the transfer to the trust, an inter vivos gift of an equitable interest in a trust is considered to have been made at that time. ...

In paragraph 5 of Supplement I to Information Circular 88-2, the Department states that the transactions described in the said paragraph for the losses utilization between a parent corporation and its canadian subsidiary, which are related corporations, are not considered an abuse of the Act read as a whole. ...