Search - considered

In particular, you requested consideration of whether: (a) taking into account the information you have provided on behalf of the Company, we would remain of the view that the mine at the XXXXXXXXXX property would constitute a mine which "has come into production in reasonable commercial quantities" for purposes of subparagraph (f)(vi) to the definition of "Canadian exploration expense" ("CEE") contained in subsection 66.1(6) of the Income Tax Act (the "Act"); and (b) if a new ore zone (referred to as "XXXXXXXXXX") is developed in the manner contemplated in a feasibility study prepared for the Company, such development would be considered a "new mine" for purposes of paragraph (g) to the above definition of CEE. ...

Pursuant to paragraph (a) of that provision, an amount is considered to qualify as a medical expense of an individual only if it is paid to a medical practitioner, dentist or nurse or a public or licensed private hospital in respect of a medical or dental service. ...

Reasons: If the foreign employer is considered a person related to the employer for purposes of 60(j.1) the years of employment with the foreign employer may be included for purposes of calculating the amount that can be transferred under 60(j.1). ...

Income from a rental arrangement is not considered income from farming. ...

Generally, an individual would be considered to have a severe mobility impairment where that individual's ability to perform the basic activities of daily living, such as walking or dressing oneself, is markedly restricted (e.g. the individual is confined to a wheelchair or has another immobilizing impairment). ...

These comments are provided in accordance with the guidelines set out in paragraph 22 of Information Circular IC 70-6R5 dated May 17, 2002, issued by the CCRA and are not considered binding on the CCRA. ...

Our Comments In our view, the cost of a stroller designed specifically for a child with special needs is only eligible for the medical expense tax credit if it can be considered a "wheelchair" for purposes of paragraph 118.2(2)(i) of the Income Tax Act (the "Act"). ...

We understand that, to the best of your knowledge and that of the Corporation, none of the issues involved in this ruling request is: (a) in an earlier return of the Corporation or a related person; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation or a related person; (c) under objection by the Corporation or a related person; (d) before the courts; nor (e) the subject of a ruling previously issued to the Corporation or a related person by the Income Tax Rulings Directorate, other than in the Ruling. ...

We understand that, to the best of your knowledge and that of the Corporation, none of the issues involved in this ruling request is: (a) in an earlier return of the Corporation or a related person; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation or a related person; (c) under objection by the Corporation or a related person; (d) before the courts; nor (e) the subject of a ruling previously issued to the Corporation or a related person by the Income Tax Rulings Directorate, other than in the Ruling. ...

Based on the advice of Natural Resources Canada, it is our view that the expenses of the underground exploration program which the Company is contemplating at the Property may reasonably be considered to relate to a potential extension of a mine that "has come into production in reasonable commercial quantities" for purposes of subparagraph (f)(vi) to the definition of CEE and would not relate to a "new mine" for purposes of paragraph (g) of that definition. ...