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Given our position that timber is not an asset distinct from the land on which it stands, the enhanced capital gains exemption could only be claimed in respect of the disposition of the land....since timber is not considered to be an asset distinct from the land on which it stands, the capital gains election cannot be filed solely in respect of the timber. ...

Finally, we confirm that it is necessary to satisfy the conditions in only one of paragraphs 251(2)(b) or 60(j.1)(iv) in order for the two employers to be considered "related" at law for purposes of paragraph 60(j.1) of the Act. ...

However, during separations of 90 days or more which occur after the 12-month period is established, the couple will not be considered spouses under the Act. ...

Also, where an individual designates a trust as a beneficiary of an insurance policy available on his death, it is our opinion that even though the terms of the trust have been established by an individual during his lifetime and separate from his will, such a trust will be considered as a testamentary trust within the meaning of subsection 108(1) of the Act as it has been created on or after the individual's death or as a consequence thereof. ...

Additional Information To the best of your knowledge, none of the issues involved in this ruling are being considered by a District Office or Taxation Centre in connection with a tax return already filed, and none of the issues are under objection. ...

You have advised us that to the best of XXXXXXXXXX knowledge none of the issues involved herein are being considered by a Tax Services Office or Taxation Centre of Revenue Canada in connection with a tax return already filed and that none of the issues are under objection or appeal. ...

As indicated in Information Circular 70-6R3, requests for a written opinion involving a proposed transaction will only be considered in the form of an advance income tax ruling request while inquiries concerning completed transactions should be directed to the appropriate Tax Services Office of Revenue Canada, as responsibility for the review of these transactions lies with such Office. ...

Given our position that timber is not an asset distinct from the land on which it stands, the enhanced capital gains exemption could only be claimed in respect of the disposition of the land....since timber is not considered to be an asset distinct from the land on which it stands, the capital gains election cannot be filed solely in respect of the timber. ...

A person is considered to be a resident of Canada if Canada is the place where he or she, in the settled routine of his or her life, regularly, normally or customarily lives. ...

To the best of your knowledge, none of the issues involved in this request is presently being considered by a tax services office or taxation centre in connection with a tax return already filed nor are any of the issues under objection or appeal. ...