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X was only selling a portion of his shares of Opco to Newco the application of GAAR would be considered. ...

The recipients remain engaged under a contract of service and are considered to be employed by IDRC. ...

The issue is whether these activities are considered to be "construction" for the purposes of the definition of that term in section 238 of draft Income Tax Regulations. ...

(c) The agreement should clearly state how the deferred amounts are held and that any amounts that may reasonably be considered to be interest accruing on the deferred amounts are paid to the employee at the end of each year as employment income (as required under subparagraph 6801(a)(iv)). ...

These comments are provided in accordance with the guidelines set out in paragraph 22 of Information Circular IC-70-6R3 dated December 30, 1996 issued by Revenue Canada and are not considered binding on the Canada Customs and Revenue Agency. ...

As well, no taxable benefit would be considered to be received by the retired employee for services provided under the plan. ...

We would expect that any equipment required to operate the website would be considered "general purpose electronic data processing equipment", as that term is defined in Regulation 1104(2) of the Income Tax Regulations (the "Regulations"). ...

Interest on borrowed funds is deductible pursuant to paragraph 20(1)(c) of the Act only to the extent that those borrowed funds can be considered to have been used for the purpose of earning income from a business or from property. ...

However, it would appear that that concept could apply in the situation you described so that the loan would be considered to have been made to the sister company of the non-resident corporation rather than to a subsidiary wholly-owned corporation of the non-resident corporation with the result that subsection 218(1) of the Act would not apply. ...

Accordingly, any changes to the tax policy or amendment to the legislation would have to be considered by the Department of Finance. ...