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The requirement to provide XXXXXXXXXX can be considered a service to be rendered in the future. ... We understand that, to the best of your knowledge, none of the issues raised in this ruling is being considered by a Taxation Services Office or Taxation Centre in connection with an income tax return already filed, is the subject of any notice of objection or is under appeal. ...

Principal Issues: Would an amount be considered reasonable retiring allowance? ... A or a related person, (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of Mrs. ...

Principal Issues: Is severance amount paid to spouse considered a retiring allowance? ... To the best of your knowledge and that of the Employer and Employee, the issues related to this request: a) have not previously been reported in the Employer's, Employee's or any related party's prior income tax return; b) are not being considered by a tax services office in connection with any of the Employee's or a related party's prior income tax return; c) are not under objection by the Employee or a related person; d) are not before the courts; and e) are not the subject of a ruling previously issued by this Directorate. ...

Interpretation Bulletin IT-221 (copy attached), which applies to taxpayers who left Canada prior to May 26, 1980, states that all relevant factors have to be considered in determining a taxpayer's resident status.  With respect to establishing whether or not his resident ties had been maintained or severed, paragraph `2 of the bulletin makes the following comments regarding a taxpayer's dwelling:      "If... he disposed bona fide of his right to occupy his dwelling here, either by sale or by lease for a time at least equal to the greater of six months and the time of the expected absence from Canada, he would ordinarily be considered to have become a non-resident. ...

Your Question Is the management income received by Corporations A, B, C, and D from Company Y considered to be income of each corporation from an active business. ... However, when a CCPC does not carry on a "specified investment business" or a "personal services business", its income received as management fees based on actual services provided will normally be considered income from an "active business". ...

We understand that the District Office has determined that certain of these artists should be considered employees of the art school rather than independent contractors (i.e. self employed). ... Factors to be considered in applying this guideline include the required investments to be made by the individual, the permanency of the relationship, and the skill required by the individual. ...

You have asked for confirmation that the employee will not be considered to have received a taxable benefit under subsection 15(1), 15(1.2), 6(15) or paragraph 6(1)(a) of the Income Tax Act (the "Act") In respect of the repurchase of shares and settlement of debt, particularly where the fair market value of the shares has fallen. ... Alternatively, if the repurchase of shares is considered independently of the settlement of the debt, it is our view that the employee would still receive a taxable benefit under paragraph 6(1)(a) of the Act if the employer repurchases the shares at an amount greater than the fair market value of the shares at that time. ...

Where, however, as in your hypothetical example, the farmer goes beyond mere subdivision of the land into lots he will be considered to have converted the land from a capital property into a trading property and paragraph 15 of the Bulletin has application. ... However, this notional capital gain will not be considered to give rise to taxable capital gains until the taxation year during which the actual sale of the lots with houses occurs.  ...

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 Income Tax Act (the "Act") in respect of which the request is to be considered. ... This subparagraph provides that any income earned by a plan trust in each calendar year (Clause (A)) or any amount that may reasonably be considered to have accrued to or for the benefit of the employee in a taxation year (Clause (B)) must be paid to the employee by December 31 of that year. 3.      ...

An amount included in income in respect of a share of a controlled foreign affiliate by reason of subsection 91(1) of the Act is added to the adjusted cost base of such shares by virtue of paragraph 92(1)(a) of the Act. 24(1) FAPI as defined in paragraph 95(1)(b) of the Act, includes only the portion of a capital gain that may reasonably be considered to have accrued after the foreign affiliate's 1975 taxation year. ... Under the common law test of residency, corporations are considered to be resident where the central management and control of the corporation actually abides.  ...