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.-     We also agree that if the farm land was leased back to the partner and the facts are such that his interest in the partnership would be considered an "interest in a family farm partnership", as defined in subsection 110.6(1) of the Act, the portion of the capital gain allocated to the partner would be eligible for the enhanced capital gains exemption provided under subsection 110.6(2) of the Act and the restriction respecting "non-qualifying real property" would not apply provided the farm land disposed of by the partnership qualifies as a "qualified farm property" of the partner, as defined in subsection 110.6(1) of the Act. ...

Based on the information provided by XXXXXXXXXX XXXXXXXXXX concern is the cost amount at which the trust governed by the merged plan will be considered to have acquired the property for the purposes of the foreign property rules in section 206 of the Income Tax Act (the "Act"). ...

Must the valuation report include a single contribution as being the amount that is considered appropriate in the actuary's opinion? ...

The level of controls included in the programme's proposed guidelines and conditions appear to be sufficient to ensure that only research projects that are specific in nature are considered for grant funding. ...

Where retirement benefits are to be funded by an insurance policy and an employer acquires an interest in the policy, the policy and all relevant documentation would have to be reviewed to determine if that interest may reasonably be considered to have been acquired to fund, in whole or in part, those benefits. ...

Where the shareholder does not deal at arm's length with the corporation the share so redeemed will be considered to have been disposed of by the shareholder at fair market value, which for the purposes of our response we assume to be equal to the redemption amount of the share. ...

Life insurance proceeds would not normally be considered to be active business assets where they are to be distributed by the corporation to fund a redemption of shares or used to fund a buy-sell agreement. ...

If the payments are considered to be made, with respect to services which may be provided on an ongoing basis, such payments may fall within subparagraph 212(1)(d)(iii) of the Act. ...

Subparagraph 148(9)(e.2)(ii) of the Income Tax Act must be considered to determine the proceeds of disposition with respect to a "policy loan". ...

As you have not provided us with sufficient details to determine whether the entity would be considered a trust or corporation we will provide you with a response for both situations. ...