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The CPP and EI may contain provisions to deem self-employed individuals hired by placement agencies to be employee for purposes of pensionability and insurability, these deeming provisions do not extend to the Income Tax Act. 1999-000473 XXXXXXXXXX Karen Power, C.A. (613) 957-8953 Attention: XXXXXXXXXX January 20, 2000 Dear Sirs: Re: Subsection 6(6) Benefits & Self-Employed Placement and Employment Agency Workers We are writing in response to your letter dated September 13, 1999, concerning the taxation and insurability of board and lodging provided to self-employed placement and employment agency workers. ...

Yours truly, Patricia Spice for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

. $25.00- 15.00 = $10.00), we believe that a benefit will have been conferred on the non-resident parent since the subsidiary is only obligated to reimburse the difference between the non-resident parent's cost of acquiring the shares and the exercise price (i.e. $20.00- 15.00=$5.00). ...

Although benefits derived from the exercise of a stock option are taxed in the year the option is exercised, the "calendar year concerned " for the purpose of paragraph 2 of Article 15 of the Convention refers to the year in which the employment was exercised. ...

Yours truly, Patricia Spice for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Yours truly, Patricia Spice for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Since your inquiry relates to a specific proposal to establish an actual arrangement, written confirmation of the tax implications may only be provided by us where the proposal is the subject matter of an advance income tax ruling request submitted in the manner set out in the Canada Customs & Revenue Agency's (the "Agency") Information Circular IC70-6R3 Advance Income Tax Rulings which may be obtained from your local tax services office or on the Internet at http://www.ccra-adrc.gc.ca/menu-e.html. ...

In our view, Guidelines 1, 2 & 3 will not apply to exempt your employment income, as you resided off-reserve and less that 50% of your duties of employment were performed on reserve. ...

Basically, "weekly rate of pay" was changed to mean an employee's annual rate of pay divided by 52.176 plus annual amounts of FSD 55, 56, & 58 to which she would have been entitled had she not been on maternity leave without pay divided by 52.176. ...

Parnanzone Attention: Karen Clarke March 20, 2000 Dear Sir/Madam: Re: XXXXXXXXXX Entitlement to the Status Indian Exemption This is in reply to your memorandum of August 18, 1999, enquiring whether XXXXXXXXXX (the " Employee"), a status Indian, is exempt from income taxation on her benefits under the Employment Insurance Act. ...