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Pursuant to subparagraph 6801(a)(iv) of the Regulations, the Plan must provide that any interest or additional amounts that may reasonably be considered to have accrued for the benefit of the employee in a year must be paid in that year to the employee. ...

Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information While an RRSP might acquire a charitable annuity as an investment the provisions of subsection 146(9) of the Act must also be considered. ...

This CDE would be allocated to the investors in the partnership pursuant to subparagraph 66.2(5)(a)(iv) on December 31, 1989 and would be considered as CDE of the investor on December 31, 1989 under these circumstances. ...

If the insurance policy is not considered to be an asset used in carrying on an active business, then substantially all of X Co.'s assets would not be used in the business, and it would no longer be a qualified small business corporation. 4.      ...

Initially, it appears that the taxpayer's business operations might satisfy the definition of each word in the phrase 'contractor's movable equipment', as indicated below: a) the vacuums, floor polishers, automatic scrubbers, etc. are considered to be equipment, b) the equipment is capable of being moved from job site to job site, and is therefore movable, and c) the taxpayer has entered into contracts with its customers to provide services for a fee and consequently meets one of the definitions of the word contractor. ...

It would not, in our view, depend on the date an investor is considered to have disposed of or acquired his shares, i.e., the settlement date. ...

We also considered David G. Broadhurst's summary in the 1989 Conference Report ("Income Tax Treatment of Foreign Exchange Forward Contracts, Swaps and Other Hedging Transactions" p. 26:13): 000321 The case law in Canada has consistently regarded payments made in connection with the financing of a company's operation as being on capital account unless the taxpayer is engaged in a money-lending business. ...

Please note that we do not comment on whether or not an individual can be considered as a trader or dealer in securities. ...

This CDE would be allocated to the investors in the partnership pursuant to subparagraph 66.2(5)(a)(iv) on December 31, 1989 and would be considered as CDE of the investor on December 31, 1989 under these circumstances. ...

In our view, a mark-up of 15% would not be considered unreasonable. The cost of providing a particular service may include the cost of the service or merely the cost of arranging for someone else to render the service depending on the circumstances in the particular instance. ...