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However, we find it surprising that our Minister's understanding of the purpose of section 31 would be considered relevant either to the validity of the assessment or to the validity, in light of the Charter of Rights and Freedoms, of the legislation itself. ...

12 January 1990 External T.I. 90M01175 F- Available-for-use Rules Unedited CRA Tags 13(27)(d)   January 12, 1990 Question 10 Available For Use Rules Under Draft paragraph 13(27)(d), is property considered capable of producing a commercially saleable product in combination with other property of the taxpayer if the property itself is capable of performing its designed function (i.e. fully manufactured) but it has not yet been attached to other modules in its final configuration? ...

It is our opinion that as long as the deferred annuity meets the requirements of subparagraph l46(1)(i.1) of the Income Tax Act (the "Act") and is purchased from a person licensed or otherwise authorized under the laws of Canada or a province to carry on in Canada an annuities business, it would be considered a qualified investment for the purposes of subparagraph 146(1)(g)(iii) of the Act. ...

If the conditions of an agreement are similar to those in paragraph 3(b) of IT-233R, the agreement is generally not considered to be a lease. ...

It is our opinion that a lump sum payment under an RRSP would not be considered as a pension payment and would therefore be subject to 25% tax under subsection 212(1)(i) of the Income Tax Act. ...

27 June 1990 Ruling HBW4125J1A F- Canada-Japan Income Tax Convention on Residence Status of Charitable Organization Unedited CRA Tags n/a 24(1) David Senécal   (613) 957-2074   HBW 4125-J1 Attention: 19(1) June 27, 1990 Dear Sirs: This is further to our letter of March 8, 1990, concerning whether a charitable organization would be considered to be a "resident of a contracting state" for purposes of the residence definition in the tax treaty Canada has with Japan. ...

Whether or not a particular subsection 15(1) benefit could be considered a distribution of income is a question of fact.  ...

Fontaine Acting Director 957-9228 Appeals & Referrals Division Subject: 24(1) v MNR Tax Court of Canada We have considered the Reasons for Judgment in respect of the above-noted case heard on November 7, 1989 and it is our view that the adverse decision should be appealed for the following reasons: 1.      2.      3.     24(1) 4.      ...

Assuming that it is an avoidance transaction, it would be considered to be a misuse of subparagraph 212(1)(b)(vii) of the Act and, for that reason, would be subject to subsection 245(2) of the Act. ...

Department's Position It is the Department's position that the fair market value of the letter of credit would be considered as a contribution to a retirement compensation arrangement. ...