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

Position TAKEN: Under existing conditions the payments are not considered to meet the criteria for deductibility set out in paragraph 60(b) and subsection 60.1(2) of the Act. ... In order for the payment to a third party in respect of the orthodontic costs to be considered an allowance payable on a periodic basis, as required by 56(1)(b) and 60(b) of the Act, it must meet the conditions set out in subsections 56.1(2) and 60.1(2) of the Act. ... In the absence of such an agreement no request for a reassessment could be considered. ...

In rare cases, when a post-dated cheque is accepted in absolute settlement of a debt, such as when both parties agree that the post-dated cheque settles the debt, the value of the post-dated cheque is considered to be income at the time it is received. ...

This bulletin indicates that tuition fees paid for, or reimbursed by an employer are not considered to be a taxable benefit if the principal beneficiary of the training is the employer. ...

However, in such a case, the value of that benefit is not considered taxable. ...

In order that an SR&ED expenditure be considered a "qualified expenditure" under the Act and, therefore, eligible for the ITC, the expenditure, among other things, must meet the requirements for deduction under paragraph 37(1)(a) of the Act. ...

What must be ascertained is whether the income of that person can be considered to be the personal property of that person that is situated on a reserve. ...

Since the responsibility for changes to the legislation falls within the jurisdiction of the Department of Finance, the proposal to amend the rules in section 31 of the Act would have to be considered by that department. ...

Where a partnership carries on business in Canada through a permanent establishment, each partner is considered to be carrying on business in Canada through a permanent establishment. ...

Where the principal reason for the agreed upon allocation may reasonably be considered to be a reduction or postponement of the tax that might otherwise have been or become payable under the Act, the Department would seek to apply the provisions of subsection 103(1) of the Act. ...