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Since the payment out of an RRSP to the trustee under the exercise of the right of offset would not fall within the foregoing exclusions, the payment would be considered as a payment of a benefit before maturity to a person other the annuitant. ...

In addition to the form of the agreement itself, it would appear that whether the "use payments" are in respect of tangible property or in respect of a secret proceed (i.e. intangible property), they would be considered rentals or royalties under the former Canada- U.S. ...

For example, subsection 110.6(7) of the Act may apply, depending on the facts of a particular situation, to deny a capital gains deduction claimed by a shareholder who is an individual in respect of the capital gain realized as a result of the application of paragraph 69(1)(b) of the Act because the corporation could be considered to have acquired its of shares for consideration that is significantly less than their fair market value at the time of acquisition, notwithstanding that the shareholder is deemed by paragraph 69(1)(b) to have disposed of his shares for proceeds of disposition equal to their fair market value. ...

On the other hand, where it is evident that the purchase by the successor company would not effect the employee's employment, 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. ...

On the other hand, where it is evident that the purchase by the successor company would not effect the employee's employment, 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. ...

In addition, paragraph 7 of IT-376 describes certain factors to be considered in determining whether a particular business is being carried on. ...

These assets are considered to be “family assets” within the meaning of paragraph 45(3)(a) of the Family Relations Act of B.C. 3. ...

For the payment to be taxable in Canada it must be considered to be "remuneration for labour or for services" within the meaning of those words in Article XI of the Canada-Netherlands Income Tax Convention (1957) (the "Convention"). ...

As was stated in the Report, the Department is reviewing the above position and until the review is completed, taxpayers may continue to rely on our published positions in IT-216, IT-437 and ATR-1 (i.e. where property is transferred to a bare trust as described in the paragraph immediately above, for all income tax purposes, the settlor will be considered the owner of the trust property). ...

M.N.R. [[1987] 1 C.T.C. 2001] (86 DTC 1842) should not be considered precedent setting. ...