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Position: No Reasons: Each drawdown is considered a separate obligation and each must be measured from date of draw to expiry date of facility XXXXXXXXXX 981683 J. ... It is the view of the Department that each such drawdown is, for the purpose of determining whether the borrower may be obliged to repay more than 25% of the principal amount of that obligation within five years from its date of issue, considered to a separate obligation of the borrower. ...

Reasons: According to Revenue Collections, XXXXXXXXXX trainees would be considered employees of XXXXXXXXXX. ... In this regard, we understand that the Revenue Collections Directorate has opined that XXXXXXXXXX training program is considered pensionable and insurable employment. ...

Paragraph 16.1(1)(b) of the Act deems that, for the purpose of computing the income of the lessee, the lessee is considered to have acquired the subject property from the lessor. ... For that same reason, such alterations or additions would not be considered to be leasehold improvements of the lessee for the purpose of a claim for capital cost allowance. ...

The determination of whether investment counsel fees or a portion thereof would be considered expenses of a RRSP trust is a question of fact that can only be determined after a review of all the facts pertaining to each particular situation. ... We have reconsidered our previous position with respect to the payment of such fees by the annuitant outside of the RRSP and we are now of the view that the payment of such fees by the annuitant would not be considered a premium or gift contributed to the RRSP. ...

The determination of whether investment counsel fees or a portion thereof would be considered expenses of a RRSP trust is a question of fact that can only be determined after a review of all the facts pertaining to each particular situation. ... We have reconsidered our previous position with respect to the payment of such fees by the annuitant outside of the RRSP and we are now of the view that the payment of such fees by the annuitant would not be considered a premium or gift contributed to the RRSP. ...

The determination of whether investment counsel fees or a portion thereof would be considered expenses of a RRSP trust is a question of fact that can only be determined after a review of all the facts pertaining to each particular situation. ... We have reconsidered our previous position with respect to the payment of such fees by the annuitant outside of the RRSP and we are now of the view that the payment of such fees by the annuitant would not be considered a premium or gift contributed to the RRSP. ...

Principal Issues: Does a note surrendered by a beneficiary of the estate which later distributes the note to the debtor considered to be a bequest or inheritance and thus escapes the application of section 80? ... Would only escape section 80 if original beneficiary had an interest in the note or surrender in the note considered to be an occurance as a consequence of death and a bequest or inheritance to the eventual debtor recipient. ...

Principal Issues: Are "special warrants" considered marketable securities for purposes of 108(2)(b)? ... Holloway Attention: XXXXXXXXXX March 12, 1997 Dear Sirs/Mesdames: Re: XXXXXXXXXX We are writing in reply to your letters of December 16, 1996 and January 29, and February 28, 1997, in which you requested a ruling that "special warrants" could be considered to be "marketable securities" for purposes of subparagraph 108(2)(b)(iii) of the Income Tax Act. ...

Although foreign currency can be bought and sold and as such could be considered a commodity, it is our position that in the context of paragraph 212(1)(b) postamble, "commodity price" should not be considered to include foreign currency fluctuations, but rather in general is to be limited to (for example) prices for tangible commodities manufactured, extracted or grown. ...

Specifically, you have requested our views as to whether (i) such income inclusion in a year for tax purposes would also be considered as income for trust purposes and (ii) this income can be considered "paid or payable" for the purpose of obtaining a deduction in computing the income of the trust pursuant to subsection 104(6) of the Act. ...