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The remuneration that the taxpayer received between Date 1 and Date 2 was, therefore, … employment income…. [T]he amount paid as compensation for cessation of employment on the day following Date 2…[and] the amounts calculated on the basis of the net salary paid between Date 2 and Date 3, and the final lump sum, if any, … were intended to compensate the taxpayer for the loss of employment and would not have received had it not been for the loss of employment. ... Furthermore, in spite of the fact that contributions of the taxpayer to the pension plans continued to accumulate for the period from Date 4 to Date 5, … the taxpayer and the employer did not have an employment relationship during that period…since [citing Schwartz] she was not required to provide services. … Thus, since… there was no beginning of employment on Date 4… the amounts paid between Date 4 and Date 5 constituted the continued payment of a retiring allowance. ...

. … [The subsequent year’s payment] is paid to the right-holder in lieu of a superannuation or pension benefit to which the right-holder would otherwise have been entitled, had it not been for the application of the UPA … [and] is to be included in the computation of the right-holder’s income for the year in which the DPBNR pays it to the right-holder. Where the right-holder is an estate, it should include the survivor benefit under s. 56(1)(a)(i) in computing its income for the year of receipt – but with a deduction to it and an inclusion to its beneficiaries being applicable where those amounts are distributed in accordance with the usual ss. 104(6), (13) and (24) rules. The Directorate went on to state, respecting where the administration of the estate has been completed prior to the DPBNR being in a position to pay the amount: [T]he CRA will not object to the beneficiaries of the estate who are entitled … to all or part of the survivor benefit amounts being considered to have received those amounts directly from the DPBNR. ...

The Directorate responded: [I]t is imperative to validate that the amount was paid or reimbursed under a services contract …. ... [A]ssuming that a contractual relationship exists between the consultants and the federal agency payer … reimbursements for travel expenses should be disclosed on the T1204 form. ...

. … Generally, the CRA considers that a presence on a weekly basis at the establishment of the employer, for a duration of the equivalent of a typical day’s work of the employee in fulfilling the employee’s normal workload, is sufficient to lead to a conclusion that the employee reports to work there. … [A]n employee who is not considered as reporting to a given establishment of the employer will be deemed to report for work at the establishment of the employer from which the remuneration is paid by virtue of subsection 100(4)…. ...

. … Subsection 108(5)… provides that amounts included in the Taxpayer’s income under subsection 104(13)… shall be deemed to be income from property that is an interest in the trust and not from any other source. … [T]he income that the Taxpayer has received is deemed to be income from an interest in a trust; it does not retain its character as dividend income. ...

. … [T]he tax-free amount available to the shareholders of a corporation (including a corporate 149(1)(n) entity), through the CDA, will generally be limited to one half of the capital gain. However, should it lose its exempt status, it also would lose its CDA under s. 89(1.2) – and the timing of the capital gains arising to it under the s. 149(10) disposition of its property would preclude those gains from being added to the available amount of its CDA. ...

. … [P]ayments such as reimbursements of tuition, bursaries or scholarships paid by an employer to help individuals continue their education can be part of a "program" …. ...

5 January 2011 Internal T.I. 2010-0386951I7 F- Résident temporaire- PFCE-- summary under Eligible Individual Summary Under Tax Topics- Income Tax Act- Section 122.6- Eligible Individual tax residency is referred to in (a) but not in (e)(ii) When asked to comment on s, 122.6(e)(ii) of the definition of "eligible individual," the Directorate stated: [T]he condition in paragraph (a) means that the individual must live with the dependant … [and that] in paragraph (c) means that the individual must be a resident of Canada for the purposes of the Act. … [T]he condition in subparagraph 122.6(e)(ii) does not refer to residency in Canada for the purposes of the Act. ...

23 June 2010 Internal T.I. 2010-0368161I7 F- 84.1-- summary under Paragraph 84.1(2.2)(b) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2.2)- Paragraph 84.1(2.2)(b) s. 84.1(2.2)(b) group can include a non-voting shareholder Three individuals (A, B, and C) each held 1/3 of the shares of Holdco, and Holdco and another individual, D, each held ½ of the shares of Opco. ... The Directorate responded: [S]ince paragraph 84.1(2.2)(b) … refers only to "shares", a person who holds only non-voting shares and another person who holds voting shares may indeed form a group of persons within the meaning of paragraph 84.1(2.2)(b) and for the purposes of applying paragraph 84.1(2)(b). ...

In responding “yes,” the Directorate stated: According to … IT-113R4, paragraph 12, pursuant to the definitions of "employee" and "office" in subsection 248(1), corporate directors are considered to be employees. ... The Queen, it was established that for the purposes of the Act, a director of a corporation is an "employee" of the corporation even though the director does not receive remuneration for the director’s services and does not provide services in the same manner as an ordinary employee. … ...