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If you have any questions concerning this matter please feel free to contact us. for Director Financial Industries Division Income Tax Rulings & Interpretations Directorate Policy and Legislation Branch ...

Lee Workman Manager Financial Institutions Section Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

Jim Wilson Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch??... ...

See file # 9801315. The tax consequence of an amount received does not arise merely because a court order has so stipulated. ...

Reasons: See File # 980159. “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. ...

Les intérêts sur l'emprunt déductibles totalisent XXXXXXXXXX $, soit la proportion des intérêts réclamés par le rapport entre la somme du capital versé des actions rachetées et des bénéfices non répartis et le montant payé pour le rachat des actions. 11. ...

The Court did, however, also specify that "This does not necessarily mean that the physical location of the Crown is irrelevant to the purposes underlying the exemption from taxation provided by the Indian Act ". ...

Principal Issues:taxation of an out of court settlement pertaining to discrimination based on sex Position TAKEN:-settlement allocation unreasonable based on reported awards under the Ontario Human Rights Tribunals-amount for lost wages employment income-a reasonable amount for mental anguish & loss of dignity would be tax exempt-reimbursement of legal fees not taxable Reasons FOR POSITION TAKEN: the lost wages are not for loss of employment since she resigned voluntarily February 9, 1995 TORONTO CENTRE TAX SERVICES Rulings Directorate Source Deductions Division A. ...

Bonner concluded that "... Mere repetition does not necessarily change the character of the activity...the level of activity shown in evidence is not indicative of the existence of a money lending business. ...

M.N.R. (85 DTC 272) both contain comments regarding what "... can reasonably be regarded as contributing to the use and enjoyment of the housing unit as a principal residence... ...