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Property is defined in subsection 248(1) of the Income Tax Act (the "Act") as: `"Property" means property of any kind whatever whether real or personal or corporeal or incorporeal and, without restricting the generality of the foregoing, includes (a) a right of any kind whatever, a share or a chose in action, (b) unless a contrary intention is evident, money, (c) a timber resource property, and (d) the work in progress of a business that is a profession;' Paragraph 1 of IT-297R2 states that a "gift" includes a "gift in kind" and paragraph 3 describes the types of property that may and may not be considered gifts in kind. ...

It does not require that premiums paid before 1992 be considered. The tax under subsection 204.1(2.1) is levied on an amount existing "at the end of any month". ...

Must the valuation report include a single contribution as being the amount that is considered appropriate in the actuary's opinion? ...

The following is a brief summary of the relevant facts: XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Our Comments: It is our view that the provisions of subsection 8503(15) of the Regulations provide for and were intended to provide for circumstances such as those being considered in XXXXXXXXXX case. ...

In our opinion the following income tax consequences occur as a result of the foregoing: (i)     the Canadian dollar equivalent ($590,000) of the amount paid to the Shareholder as a consequence of the reduction in the par value of the Preferred Shares would not be included in the Shareholder's income but would reduce the Shareholder's adjusted cost base of the Preferred Shares pursuant to subparagraph 53(2)(b)(ii) of the Act; (ii)     the return of capital on the Preferred Shares would not be considered to be a "disposition" for the purposes of the Act; and (iii)     subsection 39(2) of the Act would not apply to the Issuer or the Shareholder as a consequence of the reduction of the par value of the Preferred Shares or the return of capital to the Shareholder in respect of such shares. ...

We should point out that the Department of Finance considered it necessary to enact paragraph 18(1)(n) to specifically not allow the deduction of political donations in the computation of the income from a business or property.  ...

This position was based on the premise that the Crown cannot be placed in the position of a trustee by implication and no amounts could be considered payable or receivable until the dispute was settled. 2.      ...

" C)     In the third sentence, it says that the reimbursement of legal costs is not considered income and suggests that because of this, the amount does not form part of the retiring allowance.  ...

In order to qualify, for purposes of paragraph 55(3)(b) of the Act, you have considered the following actions. ...

It is also our understanding that in the sheltered workshop environment the majority of disabled persons are performing activities that are not considered  to be in the nature of work for the purposes of determining whether an employer/employee relationship exists. ...