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What is important is whether the individual has sufficient ties with Canada to be considered a resident of Canada. ...

In our view, such investors would not be considered to be actively engaged in the exploitation of natural resources. ...

Subsection 103(1) of the Act applies where the principal reason for the agreement to share profits in a certain manner ".... may reasonably be considered to be the reduction or postponement of the tax that might otherwise have been or become payable under this Act, the share of each member of the partnership in the income or loss, as the case may be,........is the amount that is reasonable having regard to all the circumstances..... ...

Donell Attention: XXXXXXXXXX August 10, 1995 Dear Sir: Re: Large Corporation Tax & "Stripped bonds" This is in reply to your letter of July 5, 1995 in which you have asked us whether an interest coupon stripped from a bond should, for the purpose of calculating Large Corporation Tax under Part I.3 of the Income Tax Act (the "Act"), be considered to qualify as an investment allowance pursuant to paragraph 181.2(4)(c) of the Act. ...

" Returning the original cheques and requesting the Wheat Board to reissue the cheques at a later date would not in our view be considered a "special circumstance". ...

Such a restriction is important if the plan is to qualify as a private health services plan since a plan which permits a carry-forward of credits in excess of 12 months will not be considered a plan of insurance and will therefore not be a private health services plan. ...

Our Views In our view the proceeds of disposition received by the dissenting third party would be considered to be "compensation for property taken under statutory authority" within the meaning of paragraph 54(c) of the Act. ...

The issue of whether a shareholders' agreement affected de jure control was considered in International Iron & Metal Co. ...

In the event that the "deficiency judgment" was issued prior to February 22, 1994 and becomes "statute barred" subsequent to 1996, it is our view that, generally, the Department would not seek to apply any of revised subsections 80(4) to (13) inclusive of the Act in respect of the deemed settlement of the amount which was the subject of the "deficiency judgment" as the full amount of the debt (of which the amount of the "deficiency judgment" is a portion) was previously considered in the application of old section 79 of the Act. ...

Although we cannot confirm that any payment you have described could be considered a "retiring allowance" within the meaning of subsection 248(1) of the Income Tax Act (the "Act"), we can offer the following general comments. ...