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Reasons: (a) The amount is considered to be a superannuation or pension benefit. In this case (b) the provisions of ITAR would not apply, (c) the payment would not be considered a right or thing and (d) the new proposed legislation of section 110.2 does not apply to lump sum pension surplus payments. ...

A student who is in regular attendance in a qualifying educational program is considered to be enrolled as a full-time student. ... Since regular attendance in the CGA program is one course per session, a student will be considered full-time where she is enrolled in at least one CGA course in a session. ...

You requested the following regarding the amendments to paragraph 149(1)(d): 1. an interpretation of what categories of land would be included in the expression 'geographical boundaries'; 2. whether contracts signed with the federal, provincial or municipal governments under which a portion, or the whole, of a contract has to be carried out outside of the geographical boundaries of the reserve would be considered within the geographical boundaries of the reserve; and 3. confirmation that the definition of income does not include 'grants' wherever that 'body' that pays the grant is located. ... The XXXXXXXXXX would have to be considered to be a municipality for purposes of paragraph 149(1)(c) in order for a corporation that they own to be eligible for a paragraph 149(1)(d.5) exemption. 1. ...

You have advised that, to the best of the knowledge of yourself and that of responsible officials of XXXXXXXXXX that none of the issues being considered in this advance income tax ruling request is involved in an income tax return of any of those corporations, is being considered by a Taxation Services Office or Taxation Centre of Canada Customs and Revenue Agency, is the subject of an objection or appeal by those corporations or a person related thereto, are before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, or is the subject of an advance income tax ruling previously issued. ...

However, if, in the absence of the corporation, there would be no common law master-servant relationship and the individual who undertakes to perform the services would be viewed as a self-employed individual carrying on a business, the individual would not be considered to be an incorporated employee. ... You have also asked about the expenses that a company could deduct where the company supplied drivers, operators or labourers and how a company could diversify its business so it that it would not be considered to be carrying on a personal services business. ...

Since paragraph 104(13)(a) of the Act is considered in computing net income for income tax purposes, it follows that it will also be considered in determining a person's entitlement to the GIS. ...

Accordingly, in our view, in this situation it would appear that the Individual could, at most, be considered to use 50% of the property. ... Accordingly, in our view, in the above situation it would appear that the Individual could, at most, be considered to use 50% of the property. ...

You should note that a wage loss replacement plan (WLRP) is not considered to be an EBP according to the definition of EBP in subsection 248(1). Rather, a WLRP is considered a plan to which paragraph 6(1)(f) applies. ...

A child is still considered to have resided with the annuitant if, before the annuitant died, the child lived away from home for educational reasons. If the child's net income was more than the amount described above, the child will not be considered to be financially dependent on the annuitant at the time of death, unless the child can establish the contrary. ...

We considered whether paragraph 69(1)(c) of the Act would apply to deem the Canadian resource property to be acquired by the estate at its fair market value at the time of such acquisition. ... We also considered whether paragraph 69(1)(c) of the Act would apply to deem the Canadian resource property to be acquired by the taxpayer's heir (i.e., the capital beneficiary) at its fair market value at the time of such acquisition upon the distribution of the estate's assets to its capital beneficiary. ...