Principal Issues: 1. Whether amounts paid under an agreement XXXXXXXXXX , to provide a support home for a disabled adult, are excluded from income under paragraph 81(1)(h) of the Act. 2. Whether such payments have any CPP or EI implications.
Position: 1. It does not appear that the requirements of 81(1)(h) are met. However, from the information provided, there appears to be no source of income upon which to tax the payments 2. CPP and EI implications depend on the contractual relationship, if any, with the caregivers.
Reasons: 1. Requirements of 81(1)(h). 2. If no employment and no business is carried on, the payments may have no source for income tax or CPP/EI purposes.