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The opinions expressed in this letter are not rulings and are not considered binding on the Department as outlined in paragraph 24 of Information Circular 70-6R. ...

These situations can and will only be considered on a case by case basis. ...

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 24 of Information Circular 70-6R dated December 18, 1978. ...

b)   Where a non-resident of Canada disposes of treasury bill issued after April 15, 1966 the difference between the discounted purchase price and the face value thereof is considered as interest and is exempt from withholding tax by virtue of subclause 212(1)(b)(ii)(C)(I) of the Income Tax Act.  ...

Accordingly, in the above situation, where there is only one employee covered in the plan and as the plan is not a private health services plan, the plan would not be considered to be a health and welfare trust and the exception in subparagraph 6(1)(a)(i) of the Income Tax Act would not be applicable. ...

3)     Again, assuming that the residual income is not considered "a gift of capital by way of bequest or inheritance", would the amount be excluded from the income of the foundation under clause 149.1(12)(b)(ii)(A)?   ...

However, in our view a dwelling place will not generally be considered to have been acquired for an individual's habitation unless the individual in fact "ordinarily inhabits" that dwelling, within the meaning of those words as set out in paragraph 9 of Interpretation Bulletin IT-120R3 "Principal Residence", within a reasonable time frame.  ...

Unless the conditions set out in subparagraphs (a)(vi) or (vii) of the definition of "qualified farm property" in subsection 110.6(1) are met, the property will not be considered to have been used in the course of carrying on the business of farming in Canada.  ...

In a situation wherein a company policy of the lessor would allow the lessee to purchase the leased asset from the lessor, the company policy, in and by itself, would not be considered an agreement unless the purchase option has been offered by the lessor and accepted by the lessee.  ...

The second is whether the property can be considered to have been acquired for the Taxpayer's habitation. ...