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It is our opinion that "a taxpayer" as referred to in sub-clause (d)(x)(A)(II) of Class 43.1 in the Regulations could be considered any taxpayer. ...

In general, it is our view that certain activities related to a bakery operation, such as the making of bread, could be considered to be manufacturing and processing. ...

If you wish to verify whether a specific proposed employee incentive plan will be considered an SDA, we recommend that you submit a request for an advance income tax ruling. ...

Our Comments Where tuition discounts are provided to spouses and dependent children of all eligible employees, we are of the view that the tuition discounts would be considered as a taxable benefit to the eligible employee and included on his or her T4 as such. ...

You note that it is our position that amounts reimbursed in respect of: (a) the price differential on stock options granted after the Funding Agreement has been entered into; and (b) the increase in the price differential on the pre-existing options (stock options granted to the employees of the foreign subsidiary before the Funding Agreement is entered into) that, in the circumstances, may reasonably be considered to have arisen after the date the Funding Agreement is entered into will not be included in the income of Canco under section 9 or 90, subsection 15(1) or 56(2), or paragraph 12(1)(x) of the Income Tax Act (the "Act"). ...

The comment is provided in accordance with the guidelines set out in paragraph 22 of Information Circular IC 70-6R5 dated May 17, 2002, issued by the Canada Customs and Revenue Agency (the CCRA) and is not considered binding on the CCRA. ...

As noted in paragraph 9 of IT-479R, the determination of whether a specific security transaction would be considered on account of income or on account of capital is a question of fact which can only be determined after a review of all of the relevant facts. ...

Although, as a result of the gift, the child's debt may be settled by the remittance of cash for an amount that is not less than the lesser of the principal amount of the obligation and the amount for which it was issued, it would appear that the transactions described above might reasonably be considered to be undertaken or arranged primarily to avoid the consequences of section 80 of the Act, which would otherwise apply on a straightforward forgiveness of the debt. ...

Paragraph 26 of Interpretation Bulletin IT-516R2, Tuition Tax Credit (IT-516R2) states that charges for use of library or laboratory facilities, whether identified separately or included as course or subject fees are considered eligible tuition fees. ...

The determination of whether a particular payment method is considered as a payment of interest is a question of fact and can only be made after a review of the specific facts and supporting documentation of the particular loan. ...