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However, as mentioned during our telephone conversation, a review of our files indicates that this Directorate has not previously considered the proper method of computing the earnings of a pension plan. ...

It is our view that, generally, where arm's length partners agree to share partnership income on a particular basis (whether the partners' ACB, the precise nature of the property contributed to the partnership by partners, or some other basis) and the resulting amounts allocated to partners are reasonable and the agreement may not reasonably be considered to be for the reduction or postponement of the tax that might otherwise have been or become payable under the Act such that subsection 103(1) of the Act does not apply, such agreement to share partnership income or loss would be acceptable for income tax purposes. With respect to the hypothetical situation involving Partner A, Subco and Partner B, we are unable to opine on whether subsections 103(1) or (1.1), as the case may be, would apply because the facts are not sufficient to determine whether the amounts allocated are reasonable or whether the principal reason for the agreement may reasonably be considered to be the reduction or postponement of tax that might otherwise have been or become payable under the Act. ... The Department's position with respect to these farmout arrangements is that Partner A would be considered to have acquired the interest in the depreciable property at an amount equal to its fair market value and to have disposed of an interest in the Canadian resource property for that amount, where the fair market value of the Canadian resource property cannot be determined.  ...

Such payments by the employer may include items that are normally considered personal Expenses. ... The Department considered that both these allowances were taxable. The Federal Court- Trial Division found that the social disruption allowance was taxable but that the accommodation differential was not a benefit received " in respect of, in the course of, or by virtue of the taxpayer's employment". ... The taxpayer moved at the employer's request, incurred certain expenses and suffered a loss.-     The reimbursement of expenses could not be considered a benefit since the taxpayer was simply restored to the same economic situation he was in before he moved.-     The payment had none of the qualities of a taxable allowance.  ...

Furthermore, beyond that date and until the outstanding fees and related interest are paid, no requests from XXXXXXXXXX for advance income tax rulings or for technical interpretations will be considered. ...

Furthermore, beyond that date and until the outstanding fees and related interest are paid, no requests from XXXXXXXXXX for advance income tax rulings or for technical interpretations will be considered. ...

Furthermore, beyond that date and until the outstanding fees and related interest are paid, no requests from XXXXXXXXXX for advance income tax rulings or for technical interpretations will be considered. ...

Furthermore, beyond that date and until the outstanding fees and related interest are paid, no requests from XXXXXXXXXX for advance income tax rulings or for technical interpretations will be considered. ...

Furthermore, beyond that date and until the outstanding fees and related interest are paid, no requests from XXXXXXXXXX for advance income tax rulings or for technical interpretations will be considered. ...

Furthermore, beyond that date and until the outstanding fees and related interest are paid, no requests from XXXXXXXXXX for advance income tax rulings or for technical interpretations will be considered. ...

Furthermore, beyond that date and until the outstanding fees and related interest are paid, no requests from XXXXXXXXXX for advance income tax rulings or for technical interpretations will be considered. ...