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Paragraph 3(a) of IT-337R3 states that an individual is not considered to have retired where he or she transfers from one office or position to another with the same employer (or an affiliate). ... Paragraph 3(b) of IT-337R3 states that an individual is not considered to have retired where he or she terminates employment with an employer followed by re-employment with the employer or employment with an affiliate of the employer pursuant to an arrangement made prior to the termination. ...

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). xxxxxxxxxx xxxxxxxxxx 990178 xxxxxxxxxx Attention: xxxxxxxxxx XXXXXXXXXX, 1999 Dear Madam: Re: Advance Income Tax Ruling Structured Settlement XXXXXXXXXX (the "Claimant") We are replying to your letter of XXXXXXXXXX, wherein you requested an advance income tax ruling on behalf of the Claimant with respect to a proposed structured settlement for damages arising out of personal injuries suffered by the Claimant. 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. ...

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). xxxxxxxxxx xxxxxxxxxx xxxxxxxxxx 990393 xxxxxxxxxx Attention: xxxxxxxxxx XXXXXXXXXX, 1999 Dear Madam: Re: Advance Income Tax Ruling Structured Settlement XXXXXXXXXX (the “Claimant") xxxxxxxxxx We are replying to your letter of XXXXXXXXXX, wherein you requested an advance income tax ruling on behalf of the Claimant with respect to a proposed structured settlement for damages arising out of personal injuries suffered by the Claimant. 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. ...

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). xxxxxxxxxx xxxxxxxxxx xxxxxxxxxx Attention: XXXXXXXXXX XXXXXXXXXX, 1999 Dear Sir: 990556 Re: Advance Income Tax Ruling Structured Settlement XXXXXXXXXX (the "Claimant") XXXXXXXXXX We are replying to your letter of XXXXXXXXXX, wherein you requested an advance income tax ruling on behalf of the Claimant with respect to a proposed structured settlement for damages arising out of personal injuries suffered by the Claimant. 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. ...

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). xxxxxxxxxx xxxxxxxxxx 990697 xxxxxxxxxx Attention: xxxxxxxxxx XXXXXXXXXX' 1999 Dear Sir: Re: Advance Income Tax Ruling Structured Settlement XXXXXXXXXX (the "Claimant") XXXXXXXXXX We are replying to your letter of XXXXXXXXXX, wherein you requested an advance income tax ruling on behalf of the Claimant with respect to a proposed structured settlement for damages arising out of personal injuries suffered by the Claimant. 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 v. is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

In certain circumstances, amounts paid to another person at the taxpayer's direction are considered to be received by the taxpayer. ... The amount is considered to be income or capital to the taxpayer in the same way it would have been if the taxpayer had received the amount directly. ...

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). xxxxxxxxxx xxxxxxxxxx 990183 xxxxxxxxxx Attention: xxxxxxxxxx XXXXXXXXXX, 1999 Dear Madam: Re: Advance Income Tax Ruling Structured Settlement XXXXXXXXXX (the "Claimant") xxxxxxxxxx We are replying to your letter of XXXXXXXXXX, wherein you requested an advance income tax ruling on behalf of the Claimant with respect to a proposed structured settlement for damages arising out of personal injuries suffered by the Claimant. 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. ...

However, once economic ore bodies are found, the conduct of the foreign affiliate in reference to the resource property would in our view generally be considered to disclose the purpose behind the activity associated with that property (i.e. even in respect of the period before the economic ore body was discovered) and would therefore be particularly influential in determining whether the business was an investment business. ... In order for the activities of FAl and FA2 to be considered "directly related" to the active business activities of FA3, it would generally be necessary to establish that FA3 employees conducted the full range of all the day-to-day activities necessary to explore the foreign resource property of FAl and FA2 and that were it not for the availability of the services of FA3, FAI and FA2 would not have acquired their respective foreign resource properties. ...

At the outset, we would clarify that it is generally our view that computer hardware and software may be considered as a separate asset from any building systems that it may be used to operate, such as heating/cooling systems, sprinkler systems, lighting systems and/or alarm and emergency systems. Whether or not particular computer hardware and software would be so considered in an actual situation would depend upon the facts and circumstances of that situation and the details of the particular property. ...

Principal Issues: Will the rebate to an individual (by a securities dealer) of certain commissions paid on the acquisition of Mutual funds by the individual be considered an inducement for the purposes of paragraph 12(1)(x) and also allow the individual to make an election under subsection 53(2.1)? ... To the best of your knowledge and that of the Company and Clients, the issues related to this request: (a) have not previously been reported in the Company's, Participants' or any related party's prior income tax returns; (b) are not being considered by a tax services office in connection with any of the Participants' or a related party's prior income tax return; (c) are not under objection by the Participants or a related person; (d) are not before the courts; and (e) are not the subject of a ruling previously issued by this Directorate. ...