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To do so the definition of "connected shareholder" was modified to delete paragraph (b) and new subsection 4901(2.2) was introduced so that a person is also treated as a "connected shareholder" if the person would be a connected shareholder if rights were considered. ...

For payments made after 1996, subsection 60.1(3) of the Act provides that payments made in the year of the order or agreement or in the preceding year are deemed to be paid under the order or agreement if specific provision is made that they be so considered. ...

Reasons: Once the claimant dies, the entitlement of the casualty insurer is not considered to involve damages but, under the arrangement, 50% of the remaining periodic amounts after the claimant's death will be paid to the estate and not be commuted. 971770 XXXXXXXXXX M. ...

Principal Issues: Whether two gas turbine generators each capable of producing electrical energy independent of the other considered, for purposes of paragraph (c) of Class 43.1, to be one system or two independent systems? ...

Income will be considered to be on a reserve if it is connected to the reserve, and thus one must consider and weigh all of the factors that serve to connect income to a location that is either on reserve or off reserve. ...

If the course material is related to your employment, you will not be considered to be enrolled in a qualifying educational program. ...

Principal Issues: timing of deduction for feed purchased by cash basis farmer in one taxation year when the feed will not be delivered until the next taxation year Position: no deduction until title to feed is transferred to purchaser Reasons: section 28 modifies GAAP to allow the deduction of an amount that would otherwise be accrued when it is paid, but if title to the goods has not transferred, the amount could not be considered to be for the purchase of the goods A. ...

Consequently, the full amount contributed for past services would be considered pension contributions for purposes of the Act. ...

If you take the position that there has been no division of benefit entitlements under the pension plan and the Judgment only requires a splitting of the payment then, in our view, the Taxpayer would be considered to have received the full amount of the pension and the full amount would continue to be taxed in the Taxpayer's hands. ...

Consequently, any severance pay received upon or after retirement or paid in respect of a loss of office or employment, over and above the amount that represents pay in lieu of notice, would generally be considered a retiring allowance. ...