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Situation 2 A school board accumulates funds that are held in a bank account used to administer all deposits and cheques issued.  ... With respect to the type of arrangement described above in situation 2, a determination as to whether or not such an arrangement is an RCA can be made only after considering all relevant facts.  ...

Situation 2 24(1) Our Comments 24(1) With this in mind you may wish to review the 1988 OETC claims made by these employees, This review could clarify: A)      the all or substantially all issue set out in 1) above; B)      whether the Canadian Parent or the U.S. ...

INDIAN ACT EXEMPTION for employment income GUIDELINES JUNE 1994 Revenue Canada Revenu Canada TABLE OF CONTENTS Introduction 1 Guideline 1 2 Proration Rule 3 Guideline 2 4 Guideline 3 6 Guideline 4 7 Employment-Related Income 9 Meaning of Terms Used 10 INTRODUCTION Section 87 of the Indian Act exempts from taxation the personal property of an Indian situated on a reserve. ... GUIDELINE 2 WHEN: •THE EMPLOYER IS RESIDENT ON A RESERVE; AND •THE INDIAN LIVES ON A RESERVE; ALL OF THE INCOME OF AN INDIAN FROM AN EMPLOYMENT WILL USUALLY BE EXEMPT FROM INCOME TAX. ...

X is an individual resident in Canada who directly owns a 50 acre parcel of real property (the "land"). 2.      ... Question 2 Is the answer to Question 111 different if specific underground storage rights presently exist?  ... Further, section 45 may be irrelevant because a CRP is not a capital property.  2.      ...

EXONÉRATION DU REVENU SELON LA LOI SUR LES INDIENS LIGNES DIRECTRICES JUIN 1994 Revenue Canada Revenu Canada TABLE DES MATIÈRES Introduction 1 Ligne directrice 1 2 Règle du prorata 3 Ligne directrice 2 4 Ligne directrice 3 6 Ligne directrice 4 7 Revenus liés à un emploi 9 Définitions 10 INTRODUCTION Selon l'article 87 de la Loi sur les Indiens, les biens personnels des Indiens sont exonérés d'impôt lorsque ces biens sont situés dans une réserve. ... LIGNE DIRECTRICE 2 TOUT LE REVENU QU'UN INDIEN TIRE D'UN EMPLOI SERA HABITUELLEMENT EXONÉRÉ D'IMPÔT SUR LE REVENU SI LES CONDITIONS SUIVANTES SONT RÉUNIES: • L'EMPLOYEUR RÉSIDE DANS UNE RÉSERVE; • L'INDIEN VIT LUI-MÊME DANS UNE RÉSERVE. ...

Since subparagraph 18(1)(p) refers to "the salary, wages or other remuneration paid in the year"... it is clear that a deduction under paragraph 18(1)(p) is not available for that year. 2.     The personal services corporation pays the accrued salary in the subsequent taxation year (Year 2) to the incorporated employee. With respect to 2 above you requested our opinions as to whether the paragraph 18(1)(p) deduction would be permitted in Year 2, the year the salary was paid, given that it was not made or incurred by the corporation in that taxation year (Year 2), but in the preceding year. ...

Our position remains as expressed in our previous memorandum to you dated August 15, 1988 except for the reference to the application of paragraph 2 of IT-273R. Paragraph 2 is inapplicable because the comments made in paragraphs 2 through 7 of the Bulletin are intended to refer to amounts which are "income in nature".  ... This represents a change in our previous position which was to follow paragraph 2 of IT-273R. ...

XXXXXXXXXX Dear XXXXXXXXXX: The Honourable Herb Dhaliwal, Minister of National Revenue, has asked me to reply to your letter of February 2, 1999, concerning employee automobile benefits. ... You also indicate that since the standby charge is based on the original cost of the automobile at a rate of 2 per cent per month, the whole cost of the automobile is accounted for after 4 years. ... Munir Sheikh Assistant Deputy Minister Tax Policy Branch Department of Finance Encl: Gwen Moore March 8, 1999 952-1506 2 2 ...

You describe a situation in which a trust was wound up, a new trust was created and a life insurance policy issued before December 2, 1982 was transferred from the former trust to the new trust. With respect thereto, you ask if subsection 107(2) of the Income Tax Act (the "Act") applies to allow a tax-free "rollover" of the life insurance policy and whether the policy would retain its status, in the hands of the new trust, as a life insurance policy last acquired before December 2, 1982 for the purposes of section 12.2 of the Act. ... Where there is no disposition and the transferred property is an interest in a life insurance policy last acquired before December 2, 1982, it is our view that the transferee trust would hold an interest in a life insurance policy last acquired before December 2, 1982 for the purposes of section 12.2 of the Act. ...

TEI Conference 1996 Round Table Question XV- Subsection 91(4) Please confirm that under subsection 91(4) of the Act, where an amount has been included in income in year 1 under subsection 91(1) a deduction may be taken in year 1 in respect of foreign accrual tax related to year 1 that is paid subsequently in year 2. Department's Response It is not clear why the foreign accrual tax in respect of year 1 would not be paid until year 2. Certainly the tax would be deductible in year 2 since subsection 91(4) of the Act provides that the foreign accrual tax is deductible when paid provided it is paid within 5 years of the year in which the FAPI income to which it relates was incurred. ...