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The monthly $XXXXXXXXXX arrears payments, that will be recognized by the court in an order made after April 1997, would not be considered, in and by themselves, to be a child support amount that became payable by XXXXXXXXXX under the post-April 1997 court order, but rather would represent an amount in respect of periodic support payments that became payable by XXXXXXXXXX under the 1995 court order, that had fallen into arrears. ... Consequently, an amount may still be considered to be payable on a periodic basis even when the payment is made late. ...

" However, under 4900(13) of the Regulations where a share is a qualified investment solely because of subsection 4900(12) of the Regulations, it will become a non-qualified investment for an RRSP, if: i. an individual provides services to or for, acquires goods from, or is provided services by, the issuer of the share or a person related to the issuer; ii. an amount is received by the RRSP in respect of the share; and iii. the amount can reasonably be considered to be (A) on account of or in lieu or in satisfaction of, payment for the services to or for the issuer or the person related to the issuer, or (B) in respect of the acquisition of the goods from, or services provided by, the issuer or the person related to the issuer. ... Furthermore, through the application of paragraphs (a) to (e) of the definition of "specified shareholder" in subsection 248(1) of the Act and the application of subsection 4901(2.2) of the Regulations, an annuitant of an RRSP will be considered to own all of the shares owned by the RRSP or any person not dealing at arm's length with the annuitant, a proportion of any shares owned by certain trusts and partnerships and any share that the RRSP annuitant or a related person has a right to acquire. ...

Proposed transactions may only be considered when they are presented in the form of a request for an advance income tax ruling and only where the request is made in the manner set out in the Department's Information Circular 70-6R3. ... Where an interest in an IRA is considered to be a right or thing for purposes of the Act, the legal representative of the decedent and the beneficiaries have three alternatives for reporting the decedent's interest in the IRA. ...

If an entire faculty department or part of a department pooled their funds together to buy one or more computers to be owned by the group, but shared among them, would this be considered a taxable benefit? ... If an entire faculty department or part of a department turned a portion of their professional development fund back to the College, with the condition that the College use these dollars to buy a computer to be used by the department or group, would this be considered a taxable benefit? ...

Position: While each situation must be considered on a case by case basis if the distributions are in respect of current period earnings then such amounts would be included in the computation of capital pursuant to paragraph 181.2(3)(a) of the Act. ... This is because the income and losses of a partnership are legally considered to be those of the partners. ...

In this case the security for the letter of credit is not considered to be a contribution to the RCA. ... None of the issues involved in the ruling request are, to the best of your knowledge: (i) in an earlier return of the Employer or a related person, (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Employer or a related person, (iii) under objection or appeal, (iv) before the courts, or if a judgement has been issued, the time limit for appeal to a higher court has not expired, and (v) are the subject of a ruling previously issued by the Directorate. ...

However, levies made during a year on some or all members of a trade union to provide funds for the prosecution of a legal strike of the union are considered by the courts as annual dues if the levies are capable of recurring and have not been designated by the union as “special assessments”. The interpretation of what constitutes a “special assessment” was considered by the Federal Court- Trial Division in 1987 in Darrel H. ...

Reasons FOR POSITION TAKEN: The terms of the settlement are considered to be consistent with the Department's position set out in IT-365R2 (in particular paragraphs 3 and 5). ... To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein: (i) is in an earlier return of the taxpayer or a related person; (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) is under objection by the taxpayer or a related person; and (iv) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

Although a housing unit would not normally be considered to be used in a farming business, if it is not a distinct property but forms part of the real property used in the farming business and it was never a principal residence, it may qualify for the rollover provisions of subsection 73(3) of the Act, if the entire real property on which it is part was used principally in carrying on the business of farming. ...

Reasons FOR POSITION TAKEN: The terms of the settlement are considered to be consistent with the Department's position set out in IT-365R2. ... To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein: (i) is in an earlier return of the taxpayer or a related person; (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) is under objection by the taxpayer or a related person; and (iv) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...