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The consequences to a trust and a child entering into such a transaction would best be considered after the ability to undertake the transaction is determined by the trustee. ...

As requested, we have reviewed our position and considered the arguments set out in your letter, however, it is still our view that the proposed addition of the conversion right, even if done solely at the issuer’s discretion, constitutes a circumstance under which the issuer of the obligation may be obliged to pay more than 25% of the principal amount of the obligation within 5 years. ...

Subsection 245(4) of the Act provides that subsection (2) does not apply to a transaction where it may reasonably be considered that the transaction would not result directly or indirectly in a misuse of the provisions of the Act or abuse having regard to the provisions of the Act, other than this section, read as a whole. ...

To the best of your knowledge and that of your client, none of the issues involved in this ruling is being considered by a Tax Services Office or a Taxation Center in connection with any tax return already filed and none of such issues is under objection. ...

A determination of how much land can be considered part of a principal residence in any particular case, based on a review of all the relevant facts and documentation, is normally the responsibility of the Tax Services office serving the area in which the taxpayer resides. ...

However, an essential prerequisite for an organization to be considered a religious order is the existence of vows or a specific religious discipline which sets it apart from other organizations within the religious denomination with which it is affiliated. ...

Additional Information To the best of your knowledge, none of the issues involved in this ruling request is being considered by a tax services office or taxation centre in connection with an income tax return already filed, and none of the issues is under objection or appeal. ...

Principal Issues: 1.Can profits of a foreign controlled affiliate be considered in calculating EPPS contibutions? ...

The consequence of such a position was that for purposes of paragraph 181.3(1)(a) of the Act the carrying value of the tangible property (real estate) was considered, by the insurer, to be the net amount and if the related mortgage or encumbrance was a long term debt the insurer was not including any amount with respect to the mortgage or encumbrance for purposes of computing its taxable capital in section 181.3 of the Act. ...

Further, in order for an expenditure to be considered a gift, it must be made without conditions, from detached and disinterested generosity, out of affection, respect, or charity or like impulses, and not from the constraining forces of any moral or legal duty. ...