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The CRA has defined primarily to mean more than 50%. 7. … The following factors … may be used to determine whether a premises is an establishment of a supplier: who has authority over making operational decisions in the establishment who has control of day-to-day operations of the establishment who has presence in the establishment the types of activities and routine carried on in the establishment … Example 3: attendance of such an individual at a day program of ABC … In addition to rendering care and supervision at its establishment Monday to Friday from 9 am to 3 pm, ABC includes day trips twice weekly to places such as museums, bowling alleys, and movie theatres. Since the service of providing care and supervision is rendered principally at ABC’s establishment, the supply made by ABC is an exempt supply under section 3 …. ... Throughout the day, healthy snacks are offered to the individuals at no extra cost. … The provision of care and supervision is the dominant element of the supply … [and] the transaction … constitutes a single supply of a service. ...

Income Tax Folio S2-F2-C1, Employee Professional Membership and Other Dues-- summary under Subparagraph 8(1)(i)(i) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(i)- Subparagraph 8(1)(i)(i) “Annual” requirement 1.4 … In order to be considered annual, dues must be of a recurring nature (that is, not a once and for all fee or charge paid on becoming a member). ... Meaning of recognized by statute 1.7 … Note that the status in question is that of the employee and not that of the organization or association. … Montgomery … clarified that the phrase “recognized by statute” should be afforded a broad interpretation, and that “recognized by statute” does not necessarily mean that a professional status was incorporated, created, or regulated by a particular statute.... 1.8 The term statute is generally defined to mean a law or act that is passed by a legislative body. ... In such cases, the annual dues paid to that organization may be deductible …. 1.15 An employee cannot generally deduct the annual dues paid to both a national and provincial organization, unless it is essential for the employee to belong to both organizations in order to maintain their professional status. … Dues must reasonably relate to employment income 1.16 In determining whether professional membership dues reasonably relate to the employment income source … it is not necessary that the payment of annual dues be essential for the employee to hold their position or job. ...

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The ability of … CRA … to allow an adjustment beyond the normal three-year period should not be used as a way to have issues reconsidered, such as an audit reassessment, when the individual or graduated rate estate chose not to dispute the issues through the normal objection or appeal process or where the issues were already dealt with under the objection process. … Requests affecting the statute-barred income tax return of another individual The CRA will generally not accept a request for an adjustment beyond the normal three-year period when the adjustment would result in the increase of taxes, interest, or penalties to the income tax return of another individual when that return is statute-barred and the CRA cannot reassess it. ... For more information, see … IC84-1 ….… Requests based on a court decision or other resolution CRA will generally not allow for the reassessment of a return beyond the normal three-year period if the request is made as a result of a court decision (for more information, see … IC75-7R3 …. ...