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We are of the view that the words, "an amount payable on a periodic basis" in the definition of "in subsection 248(1) of the Income Tax Act, requires that there be more than one annuity payment in a contract before it can be considered to be an "annuity" contract. ...

As discussed in our telephone conversation of August 28, 1989, advance income tax ruling requests are only considered in respect of identified taxpayers and in accordance with the guidelines contained in Information Circular 70-6R issued by Revenue Canada, Taxation (the "Department"). ...

The person would ordinarily be expected to contribute time, labour and attention to the business to a sufficient extent that such contributions would be determined in the successful operation of the business This is in contrast to a passive shareholder or investor who would not be considered to be "actively engaged" As for the phrase "actively involved on a regular and continuous basis", the regularity and frequency of involvement in the management and/or day to day activities of the farming business will depend on the nature of the farming operation and is determined on the facts of the situation.  ...

Finally, in your view the Limited Partner's expenditure base in respect of the Partnership on December 31, 1990 is $100 on the basis that the $99 payment made on February 1, 1990 is, for the purpose of subparagraph 127(8.2)(a)(ii) of the Act, an amount "described in subparagraph 53(1)(e)(iv) contributed by the taxpayer after the time he last became a limited partner of   the partnership and before the end of the year that may reasonably be considered to have increased the taxpayer's at-risk amount in respect of the partnership at the end of the taxation year in which the contribution was made. ...

Please refer to Interpretation Bulletin IT-221R2 "Determination of an Individual's Residence Status" (copy enclosed) for further information on factors to be considered in determining an individual's ordinary place of residence. ...

In determining whether the 24(1) should issue a receipt in respect of a contribution by an individual staff member, the following guidelines should be considered:-     Amounts should be paid to the 24(1) and must be unconditional.-     Any designated purpose should be part of the general activities of the 24(1) for which donations would normally be accepted.-     Generally, individuals who have made such contributions and who wish to propose that 24(1) funds be expended on particular activities should submit applications for funds or equipment to a committee responsible for administering   such funds or equipment for the particular activities.-     Such an application should adequately document the proposed use of the funds or equipment.-     Funds or equipment should only be allocated to the individual or his department after applying the standard evaluation criteria for such allocation.-     Any equipment purchased or expenditures made with contributed funds must be of such a nature that it would   be reasonable for the 24(1) to acquire such equipment or expend such funds and the usual controls with respect to the use of  24(1) equipment or expenditure of  24(1) funds should be in force.-     There can be no direct connection between the amount of the individual's contribution and disbursement from the fund or allocations of equipment to that person, nor should there be any option to purchase equipment acquired with the funds at the end of a certain time period. ...

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 21 of Information Circular 70-6R2 dated September 28, 1990. ...

It is a question of fact whether income received from a particular transaction would be considered income from a business or income from property.  ...

In this respect salary and wages are considered to be "contract debts".  ...

Where an RRSP trust is required to make first mortgage payments and the annuitant funds those payments, such funding would be considered to be contributions to the trust by the annuitant and the deductibility limits set out in subsection 146(5) of the Act would apply. ...