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The factors that are considered when determining whether a club, society or association is, in a particular taxation year, exempt from income tax as a tax-exempt, non-profit organization are set out in Interpretation Bulletin IT-496, a copy of which is enclosed for your purposes. ...

That property which would have vested in the beneficiaries in accordance with the terms of the will is generally considered to be owned by the beneficiaries from the time the trust terminated (even though the existence of the additional property was unknown). ...

The employment duties of each particular Indian employee must be considered to determine if they were in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ...

Such a restriction is important if the plan is to qualify as a private health services plan since a plan which permits a carry-forward of credits in excess of 12 months will not be considered a plan of insurance and will therefore not be a private health services plan. ...

In this regard, you ask what is considered a reasonable expense or allowance. ...

Thus, when applying the guidance provided by the Supreme Court of Canada in the 1992 Williams case that one needs to consider and weigh the factors which connect an Indian's income to a reserve, the fact that a band has a reserve is considered significant. ...

Burke, Assistant Director, Client Services Division, Calgary Taxation Services office, that the Department of Finance, in its News Release dated January 28, 1999, proposes to exclude the units of certain Canadian-based limited partnerships from being considered foreign property for investment by an RRSP or RRIF. ...

I understand that the Tax Court of Canada has considered the merits of the arguments raised in your letter in the context of your client's appeal which was dismissed on XXXXXXXXXX. ...

With respect to the tax consequences of transferring property to a trust, you may wish to note that if you transfer property to a trust for the benefit of your grandchildren, you will be considered to have disposed of the property for proceeds of disposition equal to the fair market value of the property at that time. ...

Principal Issues: Whether a gift by a Canadian resident to a NPO in the U.S. is considered to be a gift to a registered charity. ...