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It is our view that the employee will not be considered to have terminated his employment as required under the retiring allowance definition as provided in the Act. ...

Unless the transaction may reasonably be considered to have been undertaken or arranged primarily for bona fide purposes other than to obtain the tax benefit, it is possible that section 245 ("GAAR") would apply. ...

A debt is considered bad for the purpose of section 50 only when the whole amount is uncollectible or when a portion of it has been settled and the remainder is uncollectible... ...

In Gull Bay Development Corporation v The Queen 84 DTC 6040 (FCTD), the courts held that the corporation's activities were carried on for purposes other than profit despite the fact that only 50% of the corporation's staff's time was taken up with non-profit activities. 24(1)  Notwithstanding the fact that an organization may carry on a commercial operation and still be considered to be operating exclusively for a non-profit purpose, the profit-making commercial operation of 24(1) may 24(1) not be incidental to the attainment of the organization's non-profit objectives and all the revenues generated by the commercial operation may not be used to fund the non-profit activities of the organization. 24(1) In conclusion, 24(1)  This information, however, can only be obtained by reviewing, during the course of an audit, all of its activities for that year. ...

Therefore, for the purposes of calculating a taxable capital gain under paragraph 95(2)(f) of the Act of such a foreign affiliate on the disposition of its capital property, the foreign affiliate will be considered to have become a foreign affiliate of the discretionary trust at the time that the trust is deemed to be a person resident in Canada. ...

However it is the Department's opinion that the   24(1) business would be considered a manufacturing or processing activity and the capital equipment used for the    24(1)     would be eligible for class 39 treatment provided the other requirements of that class are met. ...

We agree with the opinion expressed by the Calgary District office in their letter dated March 29, 1984 (a copy of which you submitted) that the value of a stock option benefit is considered to be income from an office or employment and therefore properly subject to withholding at source by the employer although the requirement to withhold may be waived in circumstances where the withholding would cause undue hardship.  ...

6 August 1991 Ministerial Letter 911548 F- Child Care Expenses Unedited CRA Tags 63(3)(a) SUBJECT:  Child Care Expenses We have recently considered whether or not expenses paid for a child's attendance at a day camp are subject to the limitations ($60 per week or $120 per week as the case may be) in subparagraph 63(3)(a)(iii) of the Income Tax Act. ...

Whatever amount up to $100 (10% of $1,000 computed under subparagraph 66(4)(b)(i)) that the taxpayer chooses to claim in 1991 would be the amount deducted for the year and would also be considered as the amount that was deductible in 1991 for purposes of calculating the 1992 claim. ...

Accordingly, these debentures would be considered to be a foreign property if they are exchangeable for shares of a non-Canadian corporation. ...