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Safe income at a particular time with respect to a share of a corporation held by a particular shareholder is the portion of the income earned or realized by any corporation after 1971 and before that time that could reasonably be considered to attribute to the capital gain that would be realized on a disposition at fair market value of the share at that time. ...

Please refer to Interpretation Bulletin IT-221R2 "Determination of an Individual's Residence Status" (copy enclosed) for further information on factors to be considered in determining an individual's ordinary place of residence. ...

A proper request entails the provision of all related documents for our review as well as an identification of all of the specific provisions of the Act in respect of which the request is to be considered. ...

At one point the residence of the Indian was considered to have been the deciding factor. ...

At one point the residence of the Indian was considered to have been the deciding factor. ...

We confirm that the capital gains portion of payments or allocations from an EPSP to a non-resident beneficiary thereof is not considered "income from an estate or trust" under paragraph 212(1)(c) of the Income Tax Act (the "Act") in that subsection 144(4) of the Act provides that a capital gain of an EPSP is deemed to be the capital gain of the beneficiary to the extent that it has been allocated to him. ...

Pursuant to Article 18 of the Canada-United States income Tax Convention, pensions (other than benefits received under U.S. social security legislation or pensions that would otherwise be exempt from U.S. tax if you remained a resident thereof) arising in the United States and paid to a resident of Canada (i.e. you would be considered a resident of Canada upon immigration) may be taxed in both countries. ...

Deletion of uncollectible accounts is also done in accordance with the Financial Administration Act, and is considered appropriate when there is no reasonable prospect of recovery. ...

If such a proposal is considered, our division would be glad to offer its assistance. ...

The reduction determined under subsection 39(9) is considered a capital loss which the taxpayer may deal with as permitted under the Act. ...