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There are, however, publications produced by the Canada Customs and Revenue Agency which provide some guidance on what should be considered in establishing whether a particular gain is on account of capital or income. ...

As requested, we have considered the situation outlined in your letter and have provided some comments below. ...

As requested, we have considered your question and have provided some comments below. ...

Accordingly, it is Canco who would be obligated to complete and file the forms T4 and T4 Summary after the end of the calendar year in which X acquired ownership of the vehicle as a result of its purchase by Canco and by or before the end of February of that immediately following calendar year While we have provided you with our opinion(s) in reply to the questions you have asked of us, such opinion(s) are not considered binding on the Canada Customs and Revenue Agency (as provided in accordance with the practice outlined in paragraph 22 of IC-70-6R4). ...

For a discussion of factors to be considered in making these determinations, we refer you to Interpretation Bulletin 337R3 and Income Tax Technical News No. 19 both of which can be found on the CCRA website at ccra-adrc.gc.ca. ...

Notwithstanding the above, as we discussed on the telephone (Cooke/XXXXXXXXXX) on March 19, 2002, based on the limited information in your letter, one of the income tax implications that would need to be considered is subsection 55(2) of the Act. ...

You have asked whether a health and welfare trust that would otherwise meet the criteria described in Interpretation Bulletin IT-85R2, Health and Welfare Trusts for Employees ("IT-85R2"), would still be considered a health and welfare trust as described therein in a situation where no actuarial estimates are used, but the employer cannot pay more funds to the trust in a particular year than are payable in that year by the trust for benefits (a "pay-as-you-go" trust). ...

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 Canada Customs and Revenue Agency (the CCRA) and are not considered binding on the CCRA. ...

The fact that past service with a former employer is eligible to be purchased, for example, under a reciprocal agreement, does not constitute recognition of that service as required by subparagraph 60(j.1)(v) of the Act and, therefore, such eligibility, in and by itself, would not result in the former employer being considered as a "person related to the employer" for purposes of paragraph 60(j.1) of the Act. ...

In that above-noted technical interpretation, which dealt with a fact situation described in Question 22 of the 1995 APFF conference, we indicated that the application of GAAR would have to be considered if Mr. ...