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It is our view that a distribution of property by a trust to a beneficiary pursuant to the rights of the beneficiary in the trust would not be considered to be a gift for purposes of paragraph 122(2)(d) of the Act. ...

In any event, a request cannot be considered for a ruling when the transactions are completed or where the issues involved are primarily questions of fact. ...

Given the specific nature of your question we have not considered the application of any other provision of the Act in the context of your query; but we would note that the requirements of subsection 39(2) of the Act would need to be met before a taxpayer in this situation would have a capital loss. ...

Position: No Reasons: Our long-standing position is that the ability to make a payment of a patronage dividend would constitute a distribution of income for the personal benefit of a member of the co-operative, thereby disqualifying it as an NPO. 2003-003653 XXXXXXXXXX Kimberly Duval (613) 957-8982 January 22, 2004 Dear XXXXXXXXXX: Re: Patronage Dividends and Non-Profit Organizations We are writing in reply to your letter of August 15, 2003 wherein you requested our general views regarding whether the payment of patronage dividends would disqualify a corporation from being considered a non-profit organization within the meaning assigned by paragraph 149(1)(l) of the Income Tax Act (the "Act"). ...

However, if it is clearly to the employer's advantage for an employee to be a member of a club, the employee will not be considered to have received a taxable benefit. ...

As stated in paragraph 2 of interpretation bulletin IT-122R2, United States social security taxes and benefits, "disability insurance benefits paid under the Social Security Act up to the age of 65 are not considered to be income and therefore are not subject to tax in Canada. ...

We indicated that travel between an employee's home and a regular place of employment is considered personal in determining the taxable status of employment benefits in respect of use of an employer provided automobile. ...

The rule can be considered a "levelling" of the interest rates over the term of the instrument. ...

Therefore, this would be considered a prohibited advantage subject to the penalty in subsection 146(13.1) of the Act such that the issuer would be liable to a penalty equal to the greater of $100 and the amount or value of the advantage. ...

As noted in paragraph 7 of IC 73-13, an investment club will generally only be considered to be a bona fide investment club where, among other things, all of its members are individuals. ...