s. 248(21) applicable where partition of parcels as between the interests of two equal co-owners but with minority co-owners maintaining their interests in all the parcels
Principal Issues: Partitioning some land with some minority co-owners remaining co-owners in all the parcels after the partition.
Position: Ruling issued.
Reasons: The requirements in subsection 248(21) are met.
Principal Issues: Whether employment income would be considered situated on a reserve and thus exempt from tax.
Position: Likely.
Reasons: Guideline 4 does not likely apply to the situation. However, there appears to be connecting factors that could situate the employment income on a reserve.
