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An association, in order to be considered "approved" for the purposes of section 37 of the Act, must receive written approval from our Minister. 2. ...

We have also considered the provision of paragraph 118.2(2)(o) of the Act which deals with amounts paid for laboratory, radiological or other diagnostic procedures or services prescribed for a patient by a medical practitioner or dentist. ...

You seek further clarification on how Revenue Canada has determined that financial assistance for training provided to Employment Insurance (EI) clients under the New Brunswick Skills Loans and Grants program are considered taxable to the recipients. ...

An association, in order to be considered "approved" for the purposes of section 37 of the Act, must receive written approval from our Minister. 2. ...

You provide the following set of hypothetical facts. 1) Newco, a corporation resident in the United Kingdom, issues a debt instrument (the “Newco Debt”) to its Canadian parent (“Canco”) as consideration for shares of a related United Kingdom company. 2) The interest on the Newco Debt is not deductible in computing taxable income for United Kingdom income tax purposes. 3) The interest on the Newco Debt, when paid will be considered a distribution of a dividend for United Kingdom tax purposes which requires the payer (Newco) to withhold and remit advance corporations tax (“ACT”). ...

Under that definition, if the total area of the contiguous land upon which a housing unit is situated exceeds 1/2 hectare, the excess land is considered not to have contributed to the use and enjoyment of the housing unit as a principal residence, unless it is established that the land in excess of 1/2 hectare was necessary for such use and enjoyment. ...

Where a mortgage has been acquired by a self-directed RRSP and the mortgage is considered to be a qualified investment, it is the Department's view that such an acquisition has no immediate tax consequences to the RRSP's annuitant. ...

We understand that, to the best of your knowledge, none of the issues raised in this ruling are being considered by a Taxation Services Office, no tax return has yet been filed by the XXXXXXXXXX (the "Corporation"), and no member has yet filed a return reporting the deduction of such fees. ...

Thus, an amount contributed to an RRSP can be designated as a repayment under the home buyers plan, but it would not be considered a premium that would reduce the Part X.5 tax nor would it be deductible under subsection 146(5) or (5.1) of the Act. ...

Constructive receipt is considered to occur in situations where an amount is credited to an employee's debt or account, set apart for the employee, or otherwise available to the employee without being subject to any restriction concerning its use. ...