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You have further asked whether the gain, cost recovery or royalty would be considered to be income other than that contemplated in subparagraph 133(8)(d)(ii) of the Act ("Qualifying Income"), such that the transferor would lose its status as an NRO. ...

For example, if you disposed of your Treasury Bill prior to maturity ad received proceeds at the same effective rate of return you would have received had the Treasury Bill been held to maturity, all of the proceeds in excess of your adjusted cost basis would be considered to be interest income.  ...

The opinions expressed herein are not advance income tax rulings and in accordance with paragraph 21 of Information Circular 70-6R2 dated September 28, 1990 are not considered binding on the Department. for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch9104000- 9104999 ...

Delete last line and insert "a province, but who are considered residents of Quebec for the purposes of the Quebec Income Tax Act. ...

In the situations described above, control would normally be considered to be acquired on closing, when title to the shares passes, unless the purchase and sale agreement provides otherwise.  ...

Jones   (613) 957-2104 April 9, 1990 Dear Sirs: Re: Subsection 7(1.1) of the Income Tax Act (the "Act") This is in reply to your letter of February 2, 1990, wherein you requested our opinion with respect to several hypothetical situations as to whether the arrangements would be considered a stock option agreement qualifying under subsection 7(1.1) of the Act. ...

A proper request entails the provision of all related documents for our review as well as an identification of all of the specific provisions of the Act in respect of which the request is to be considered. ...

However, the taxability of annuity payments depends largely on the arrangements and structure of the annuity. b)     Where the capital element of the annuity vests indefeasibly in the beneficiary at the time of purchase, then the individual would be considered to have constructive receipt of the amounts paid by the former employer to purchase the annuity.  ...

The comments expressed are not advance income tax rulings and are not considered binding on the Department, in respect of any taxpayers, in accordance with paragraph 21 of Information Circular 70-6R2 dated September 28, 1990. ...

Further, it is our view that disability insurance premiums cannot be considered to be "a standby charge, guarantee fee, registrar fee, transfer agent fee, filing fee, service fee or any similar fees, for the purposes of paragraph 20(1)(e.1) of the Act and are therefore not deductible under that provision. ...