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As was noted during our above-referenced telephone conversation, in our opinion it is a question of law as to whether at a particular time, an estate beneficiary is entitled to enforce payment of the income or capital of the estate and whether beneficial ownership of a property is considered to have passed to the beneficiary. ...

Whether an excess EPSP amount is considered compensation for RPP purposes. 2. ...

/ Whether the House of Commons can be considered a public body performing a function of government pursuant to 149.1(1)? ...

Therefore, where the reimbursement is for reasonable voice and data services required for employment purposes, an employee would not generally be considered to have received a taxable benefit. ...

Any proposal to change legislation must be considered by the Minister of Finance and approved by Parliament. ...

When an RRSP or RRIF trust exercises a conversion right attached to an existing security and exchanges it for a new security, the RRSP or RRIF trust is considered to have acquired the new security. ...

As noted in paragraph 7 of IT-529, where flex credits have no redemptive value and nothing of value is forfeited by the employee to acquire such credits, the flex credits are considered to be notional amounts with no intrinsic value. ...

Generally, an amount required to be paid or an amount due is considered an amount payable. ...

CRA Tags 143.4(1) 80(1) Principal Issues: Whether a contingent amount under the definition of this term in subsection 143.4(1) would be considered an excluded obligation within the meaning of the definition of this term in subsection 80(1)? ...

The CRA's response at the 2010 Canadian Tax Foundation Conference with regard to the question of whether CRA would be willing to issue a certificate pursuant to section 116 where the shares to be disposed would not be considered to be taxable Canadian property, was as follows: "The CRA does not review or make a determination of whether a property is taxable Canadian property in the course of processing a section 116 certificate request. ...