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Paragraph 40(2)(e.1) of the Act provides that the loss from the disposition of certain indebtedness is considered to be nil where the transferor and the transferee are related to each other. ...

It is our general view that an employee will be considered to have received a taxable employment benefit when an employer reimburses the employee for part, or all, of the cost of an asset purchased and owned by the employee, notwithstanding that the asset may be partly used for employment-related purposes. ...

In our view, such lesser amount would reduce the payer corporation's RDTOH pursuant to paragraph 129(3)(d) because it would still be considered to be a dividend refund whether or not it is actually received by that corporation. ...

In general, the issues that are to be considered in making such a determination include, but are not limited to: 1. whether the expenses are reasonable in the circumstances, 2. whether they are incurred in connection with the operation of the plan, and 3. whether they would normally be incurred by an RPP in fulfilling its plan obligations. ...

The Tax Court of Canada has considered the issue of whether the cost of a hot tub is a qualifying medical expense in a number of cases, with the Court allowing the cost of a hot tub in some instances, and not allowing it in others. ...

However, for your records, we wish to confirm that we considered the further comments from XXXXXXXXXX letter to us (copy attached) and stand by our conclusion in our December 23, 1999 memorandum. ...

These comments are provided in accordance with the guidelines set out in paragraph 22 of Information Circular IC 70-6R4 dated January 29, 2001 issued by the CCRA and are not considered binding on the CCRA. ...

In addition, where such shares are held by a corporation and are subsequently redeemed, the application of subsection 55(2) to any taxable dividend arising on the share redemption must be considered. ...

Thus, you should contact that Department if you wish to obtain information on any new tax policy initiatives being considered as a result of the decision in 65302 British Columbia Ltd. ...

Position: Generally, no Reasons: Jurisprudence XXXXXXXXXX 2001-007514 Cornelis Rystenbil, CGA April 20, 2001 Dear XXXXXXXXXX: Re: Breeding of Dogs This is in reply to your letter of March 15, 2001 in which you ask for our views on whether the breeding of purebred dogs with the intent to earn a profit is considered to be a farming activity under the Income Tax Act (the "Act"). ...