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ADM'S Office (2) 97-07547M Return to Rulings, 15th Floor, Albion Tower Pending XXXXXXXXXX Dear XXXXXXXXXX: The Honourable Herb Dhaliwal, Minister of National Revenue, has asked me to reply to your letter of November 9, 1997, concerning the filing date for T3 slips by a mutual fund trust. ... Yours sincerely, Denis Lefebvre Assistant Deputy Minister Policy and Legislation Branch George Keable 957-2046 February 10, 1998 973381 Finalized March 2, 1998 LC/gt ...

ADM'S OFFICE (2) ADM972874 RETURN TO 15TH FLOOR, ALBION TOWER January 26, 1998 XXXXXXXXXX Dear XXXXXXXXXX: I am replying to your letter of November 10, 1997, concerning the application of the Indian Act exemption for employment income. ... Generally, the Guidelines provide that the tax exemption will apply to exempt all the employment income of a status Indian from a particular employment: 1) where substantially all the duties of employment are performed on a reserve; 2) where the Indian lives on a reserve and the employer is resident on a reserve; 3) where more than half the duties are performed on a reserve and either the Indian lives on a reserve or the employer is resident there; and 4) where the employer is resident on a reserve, the duties are part of certain non-commercial activities of the employer and the employer is an Indian band, tribal council or Indian organization described in Guideline 4. ...

6 May 1998 Ministerial Letter 9804488 F- DEDUCTIBILITE POUR EN AUTOMOBILE Unedited CRA Tags 2 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Herb Dhaliwal Alain Godin 957-2128 Le 2 mars 1998 ...

The Department of Finance responded to those recommendations on October 2, 1996, by announcing draft amendments to the Act, which, when enacted, will be effective as of that date. ... Yours sincerely, Bill McCloskey Assistant Deputy Minister Policy and Legislation Branch Attachment George Keable (613) 957-2046 September 16, 1998 982309- 2- ...

In your situation, depending on where the partnership as employer is resident, where the employee is resident, and where the duties of employment are performed, any of Guideline 1 and the proration rule, Guideline 2 or 3 could apply to exempt the employment income. ... Yours sincerely, Bill McCloskey Assistant Deputy Minister Policy and Legislation Branch Attachment Author: Roxane Brazeau-LeBlond 957-2136 November 4, 1998- 2- ...

Several recent court decisions, including Reference Re Goods and Services Tax [1992] 2 Canada Supreme Court Reports 445, Kasvand v. ... Section 2 of the Income Tax Act is the statutory provision that compels every person resident in Canada who has taxable income to pay income tax. ...

Under Guideline 2, where the employment duties of Indians are performed entirely off a reserve, the employment income earned will be tax-exempt if the employer is resident on a reserve and the Indian lives on a reserve, except where it can reasonably be considered that one of the main purposes for the existence of the employment relationship is to establish a connecting factor between the income in question and a reserve. Indians working for your organization would not be exempt from tax under Guideline 2 if the only factor connecting the employment income to a reserve is the residence of the employee leasing agency which employs the Indians. ...

AUTHOR SUBJECT OR CORPORATE FILE XXXXXXXXXX Dear XXXXXXXXXX: I am writing in reply to your letter of September 26, 1994, wherein you requested our comments regarding the application of the Indian Act Exemption for Employment Income Detailed Guidelines (the "Guidelines") to Indians who perform their duties on lands to which title has never been absolutely surrendered by the XXXXXXXXXX In your opinion, XXXXXXXXXX the employment income earned by the Indians is exempt from tax under either Guideline 1 or 2. ... As regards Guideline 2, it will apply only if the employer is resident on a reserve and the Indians live on a reserve. ...

DM'S OFFICE (2) YS # 95-0049817 ADM'S OFFICE (2) RETURN TO RULINGS, AUTHOR SUBJECT OR CORPORATE FILE SECTION CHIEF March 13, 1995 XXXXXXXXXX Dear XXXXXXXXXX: The Honourable David Anderson, Minister of National Revenue, has asked me to reply to your letter of December 22, 1994, concerning the taxation of Indians. ...

Result of major revisions to the ITA in 1971 (when PHSP def'n first introduced) Reasons FOR POSITION TAKEN: based entirely on statute ASSOCIATE DEPUTY MINISTER (1) ADM'S OFFICE (2) RETURN TO 15TH FLOOR, ALBION TOWERS XXXXXXXXXX June 7, 1995 Dear XXXXXXXXXX: The Honourable David Anderson, Minister of National Revenue, has asked me to respond to your letter of March 15, 1995, in which you ask when and why medical premiums became taxable benefits for certain individuals. ... SHORT 957-2136 JUNE 2, 1995 ...