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Comments We maintain the view expressed in our document dated September 13, 2000 (# 2000-0042885) that a derivative agreement such as a swap or forward contract is a contractual arrangement separate from any associated asset or liability for which it may be designed to hedge. ...

The taxpayer referred to two documents (#9032185 and # 2002-0152203) issued by the Canada Customs and Revenue Agency (the "CCRA") to support their arguments. ...

Reasons: See File # 980159 and 983032. "Travel expenses" includes air, train and bus fares, meals, hotel and motel accommodations, camping fees, incidentals such as taxis, road and ferry tolls, and automobile expenses directly related to the trip such as the cost of fuel, general maintenance (ex. oil, grease and servicing charges), repairs, licenses, and insurance as long as the costs are reasonable, are not on account of capital, and can reasonably be attributed to the trip. ...

In stating that the definition of partnership would be satisfied, even where profit making or profit sharing was such an ancillary purpose, Bastarache J. cited the following extract from Lindley & Banks on Partnership: "...if a partnership is formed with some other predominant motive (other than the acquisition of profit)... but there is also a real, albeit ancillary, profit element, it may be permissible to infer that the business is being carried on "with a view to profit". ...

April 27, 2000 Bharat Patel Resource Industries Section Oil & Gas Specialist A. ...

.), J.L.Guay Ltee, 71 DTC 5423 (FCTD) and Newfoundland Light & Power Co. ...

" As stated in this excerpt, the profit and loss experience is a factor in assessing whether a reasonable expectation of profit is present. ...

The term "Indian", as used in the Guidelines, is defined on page 10 of the Guidelines to mean "an Indian as defined for purposes of the Indian Act ". ...

Brian Arnold's article "Canada Amends Income Tax Convention Interpretation Act " published in Tax Notes International, vol. 18, Number 6, February 8, 1999. ...

" The Supreme Court of Canada found in Savage, 83 DTC 5409 and Nowegijick, 83 DTC 5041 that the words "in respect of" are "... of the widest possible scope. ...