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As mentioned in paragraph 6 of Interpretation Bulletin IT-500, for purposes of subsection 146(8.91) of the Act, the deceased's legal representatives will be considered to receive amounts "for the benefit of the spouse" where, as a result of a disclaimer by another beneficiary of an interest in the estate, the residue including the funds derived from the plan is distributed to the spouse. ...

1 August 1991 Ministerial Letter 911898 F- Trade in Securities Unedited CRA Tags n/a Subject:      24(1)    Trade in Securities This is in reply to your memorandum of July 18, 1991, wherein you request a opinion as to whether   24(1)                    would be considered a trader in account receivables.  ...

The comments expressed are not advance income tax rulings and are not considered binding on the Department, in respect of any taxpayers, in accordance with paragraph 24 of Information Circular 70-6R dated December 18, 1978. ...

As noted in paragraph 2 of Interpretation Bulletin 124R5, reasonable administrative fees paid by an annuitant to the trustee of an RRSP are considered to be deductible expenses in computing income from property, since such administrative fees relate to services provided by the trustee of the RRSP. ...

You understand Revenue Canada's interpretation is that neither the Superallowance nor OCCA is considered an inducement, subsidy, deduction from tax, allowance, contribution or any form of assistance for the cost of the asset acquired or expense incurred by the taxpayer.  ...

Consequently, it is our view that this amount is employment income pursuant to subsection 5(1) and/or 6(3) of the Act and that the amount cannot be considered a retiring allowance. ...

In light of the supplementary funding as well as other non-financial support provided it seems clear that the parents would be considered to be supporting their children resident at the  24(1)   It then follows that a claim for the personal credit in respect of a dependent child would be allowed to the parent reporting the family allowance, and as a result, where the criteria have otherwise been met, a claim for the disability credit would also be in order. ...

We agree that payments on account of a debt would not be considered distributions for purposes of subsections 159(2) & (3).      24(1)     21(1)(a)      21(1)(b) We trust this will be of assistance to you. ...

While it may be arguable that the fluctuation in a commodity price and the fluctuation in a foreign currency would not be considered the same criterion with reference to which interest could be computed, it is our opinion that they could fall within the term "similar criteria". ...

Accordingly, in applying the provisions of paragraph 206(1)(d.1) the appropriate test, in our view, is to determine if greater than 50% of the value of a share being considered is derived directly or indirectly from investments in foreign property. ...