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As long as that portion of the premium is accounted for separately and, if paid by the employer, added to the employee's income as a taxable benefit, then the group term life insurance policy in respect of the employee will not be considered tainted by such additional coverage. ...

The interest reimbursement would be considered income and includable in the farmer's income.  ...

An individual is employed outside of Canada and is considered to be a non-resident for tax purposes.  ...

In addition, paragraph 19 of IT-259R2 indicates that a taxpayer who changes from one business category to another but continues to deal in the same product will normally be considered to be in a "similar business". ...

We would further note that, with respect to both of the above referenced types of assets, property which is acquired and held in the ordinary course of a particular business is considered to be "used in Canada" for purposes of the calculation. ...

Advance tax rulings will continue not to be available for such arrangements where one of the main reasons for the arrangement can reasonably be considered to be to circumvent the at-risk rules. ...

Pension income is considered an "other" source of income as defined in section 56 of the Act. ...

If you encounter cases where you believe the facts differ in substance from those considered in the attached memoranda, we would be pleased to provide our comments in response to a request from you. ...

23 December 1991 Administrative Letter 9134466 F- Tuition Tax Credit Post-Secondary Course Unedited CRA Tags 118.5(1)(a)(i) 24(1)  —  118.5(1)(a)(i)  —  91–8592T We are writing in reply to your memorandum of December 13, 1991, wherein you requested our views as to whether or not (the college) would be considered to be an "other educational institution" for purposes of subparagraph 118.5(1)(a)(i) such that (the taxpayer) would be entitled to the tuition tax credit in respect of tuition fees paid to the college for the 1988 and 1989 taxation years. ...

Spice 952-9853  Bob Reynolds 7-920067 Subject: "Connected Persons"- Regulation 8500(3) This is in reply to your memorandum of December 24, 1991, in which you ask us to review a letter of May 29, 1991 from 24(1) (a copy of which was enclosed with your memorandum) concerning the above-noted matter. 24(1) will be submitting a formal application for registration of a pension plan and wishes to know if the Department would view a certain employee as a "person connected with the employer" in the circumstances described in its letter. 24(1)       Subsection 8500(3) of the Income Tax Act Regulations describes which individuals are to be considered connected to an employer.  ...