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Principal Issues: whether an allowance or reimbursement to an employee for either employment related consumable supplies or for durable assets like a computer is included in income Position: allowances of both types are included in income but if the amount is a reimbursement of a consumable employment-related supply, it is excluded from income- if it is a reimbursement of a durable good or of a personal expense, it confers a economic benefit and is taxable to the employee under 6(1)(a) Reasons: 6(1)(b) contains no exclusion for either type of allowance and 6(1)(a) will require the reimbursement of a employee's cost of a durable good to be included in income in that the employee has effectively acquired an asset at a lower cost than s/he would have if the employer had not assisted note that the Dept's response to Huffman was that both an allowance & a reimbursement of special clothing which had no personal value was is excluded from income- the quantum of such allowances, when paid as allowances, is usually such that it is reasonable to assume that the employee likely did spend the full amount of the allowance because it would be unreasonable to expect the employee to spend less- if it is likely that the employee may not spend the full amount of the allowance, then it should be included in income MINISTER/DEPUTY MINISTER'S OFFICE 97-02057M ADM'S OFFICE RETURN TO 15TH FLOOR, ALBION TOWER May 1, 1997 XXXXXXXXXX Dear XXXXXXXXXX: I am writing in respect of a question raised by one of your constituents concerning the taxation of allowances paid to university professors for expenses incurred in relation to their employment. ...

MINISTER # 97-02639M DEPUTY MINISTER'S OFFICE (2) ADM'S OFFICE (2) PENDING RETURN TO INCOME TAX RULINGS AND INTERPRETATIONS DIRECTORATE 15TH FLOOR, ALBION TOWER Signed on XXXXXXXXXX Dear XXXXXXXXXX: I am writing in response to your letter of April 8, 1997, concerning the requirement, under a deferred salary leave plan, that an employee return to his or her regular employment for a period that is not less than the leave of absence. ...

Principal Issues: why fed employees, RCMP & others can receive up to $47 a day for meals but a trucker may only deduct $16.50 per day for meals Position: The $47 per diem refers to daily travel allowances which may be received in certain circumstances without having to be included in income. ...

Spice Director General (613) 957-8953 Attention: Wayne Warren Correspondence Section 942791 Minister's Mail Insert for Docket # 94-1533D Client's Name: XXXXXXXXXX Topic: Direct Transfer Pursuant to Subsection 147.3(4) of the Income Tax Act This is in reply to your memorandum received October 31, 1994, in which you ask us to provide an insert for the above-noted correspondence. ...

McInnis GST Policy & Legislation 954-7954 October 31, 1994 Domus 1396 ...

. # 96-00997M ADM'S OFFICE RETURN TO 15TH FLOOR, ALBION TOWER April 15, 1996 XXXXXXXXXX Dear XXXXXXXXXX: I am writing in reply to your letter of February 7, 1996, written on behalf of your constituent, XXXXXXXXXX concerning the payment received from his employer. ...

PROPOSED CHANGES TO THE INCOME TAX ACT WILL REQUIRE INCOME BENEFITS UNDER NCARP TO BE INCLUDED IN INCOME UNDER — 56 OF THE ACT UNLESS OTHERWISE REQUIRED TO BE INCLUDED IN INCOME. ...

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. ...

XXXXXXXXXX suggested that the fourth guideline provide an exception for " XXXXXXXXXX or group dedicated, but not necessarily exclusively dedicated, to the social, cultural or economic development of Indians who for the most part live on or are entitled to live on reserves. ...

Principal Issues: Recovery of rrsp losses Position: General comments provided Reasons: The Act does not provide for any recovery of losses in an RRSP MINISTER/DM'S OFFICE YS # 95-07194M ADM'S OFFICE PENDING RETURN TO 15TH FLOOR, ALBION TOWER Signed on November 29, 1995 XXXXXXXXXX Dear XXXXXXXXXX: I am replying to your letter of September 26, 1995, on behalf of your constituent, XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX has requested that the federal government encourage his former employer to guarantee 100 per cent recovery of the retirement savings in the group RRSP held by XXXXXXXXXX, and to consider enacting legislation to ensure employer-sponsored group RRSPs are protected in the future. ...