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You have asked whether (a)an interest benefit under 80.4(2) of the Act would be assessed from the time the cash was withdrawn from the company to the date of the corporate resolution or (b)no interest benefit would be assessed as the dividends would be considered to have been paid on the day that the cash was withdrawn from the company and therefore no amount would be owing from the shareholder at any point in time. ...

In order for an organization to be considered to be resident on reserve, the central management and control over the organization would have to be exercised on reserve. ...

The comments expressed are not advance income tax rulings and are not considered binding on the Department, in respect of any taxpayer, in accordance with paragraph 21 of Information Circular 70-6R2 dated September 28, 1990. ...

As discussed in our telephone conversations, the issue of whether the general anti-avoidance rule ("GAAR") in section 245 of the Income Tax Act (the "Act") will apply to a transaction involving debt of a trust and the foreign property rules in section 206 of the Act has been considered by the Canada Customs and Revenue Agency (the "CCRA") on several occasions. ...

Therefore legislative amendments to the Income Tax Act will be considered in order to provide continuity in this important area of the law. ...

Paragraph 35 of interpretation bulletin IT-470R(Consolidated), Employees' Fringe Benefits, states, Where an employer reimburses an employee for the expenses incurred by the latter in moving the employee and the employee's family and household effects either because the employee has been transferred from one establishment of the employer to another or because of having accepted employment at a place other than where the former home was located, this reimbursement is not considered as conferring a taxable benefit on the employee. ...

As a result of the stock split, none of the shareholders of the particular corporation will be considered to have disposed of their shares for the purposes of the Act. ...

The determination of whether education assistance paid is considered tax exempt for purposes of the Income Tax Act is always a question of fact. ...

Specifically, travel between an employee's personal residence and the employer's place of business where the employee ordinarily reports for work is generally considered personal in nature. ...

Position: The difference between the consideration received and FMV is considered a benefit to the RRSP annuitant. ...