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In our view an amount paid to a school, institution or other place for residential care would not be considered "remuneration" and thus would not be "remuneration for an attendant" even though the fees paid may be used by that school, institution or other place to pay the remuneration of its staff. ...

ANALYSIS In our view the crux of the issue is whether the condition in paragraph 8502(b) of the Regulations can be satisfied, namely, that the contributions used to satisfy an unfunded liability can be considered to be "in respect of the member's benefits". ...

Since all of these groups will have one member that controls the corporation, each group of persons will be considered, by virtue of subparagraphs 84.1(2)(e)(ii) and (iii), to control the corporation. ...

The issue has been considered most recently in the courts in the case of Her Majesty The Queen v. ...

The age limitation was added because sixteen years is considered, in most cases, to be a reasonable and traditional age for job training to commence. ...

Principal Issues:-Would the corporation be considered wound-up for purposes of the Act in a situation where the corporation is not dissolved? ...

Subject to certain specified exceptions, a corporation is considered to be "controlled, directly or indirectly in any manner whatever" pursuant to subsection 256(5.1) of the Act if a "controller" (as defined therein) has any direct or indirect influence that, if exercised, would result in control in fact of the corporation. ...

You wish to know when an asset will be considered to be used in an active business for the purposes of subparagraph 110.6(1)(c)(i) of the definition of a "qualified small business corporation share". ...

We concur your views that according to paragraph 9 of Interpretation Bulletin IT-385R2, where a taxpayer for no consideration validly surrenders his/her income interest in a trust and does not direct the manner in which the income interest is to be distributed, he/she will not be considered to have received any proceeds of disposition for the purposes of subsection 106(2) of the Act. ...

While there is a presumption that "free tuition" would normally constitute a benefit and that the student would accordingly not be entitled to the education tax credit, it is our view that a student participating in a program which is available to the public at large would not be considered to have received a benefit solely by reason of the fact that tuition was not charged for that program. ...