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You advise that to the best of your knowledge and that of the taxpayers referred to above, none of the issues involved in the ruling request: are in an earlier return of the taxpayers or related persons, are being considered by a taxation services office or a taxation centre in connection with a previously filed tax return of the taxpayers or related persons, are under objection by the taxpayers or related persons, are before the courts, and are the subject of a ruling previously issued by the Directorate. ...

To the best of your knowledge and that of the Company and Clients, the issues related to this request: (a) have not previously been reported in the Company's, Participants' or any related party's prior income tax returns; (b) are not being considered by a tax services office in connection with any of the Participants' or a related party's prior income tax return; (c) are not under objection by the Participants or a related person; (d) are not before the courts; and (e) are not the subject of a ruling previously issued by this Directorate. ...

This value is an amount equal to a prescribed amount per kilometre for operating costs in connection with personal use and a "reasonable standby charge" (plus the equivalent to the Goods and Services Tax (GST) on the standby charge). ...

To the best of your knowledge and the knowledge of the Employees, none of the issues involved in this request for an advance income tax ruling: (a) is in an earlier return of the Employees or of a person related to the Employees; (b) is being considered by a tax services office or tax centre in connection with a previously filed return of the Employees or of a person related to the Employees; (c) is under objection by the Employees or by a person related to the Employees; (d) is before the courts; or (e) is the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate, other than the Previous Ruling described in 5 above. ...

Under the Canada Revenue Agency’s (CRA) revised PHSP position, a plan qualifies as a PHSP where: i. all of the expenses covered under the plan are medical or hospital expenses (medical expenses), or expenses incurred in connection with and within a reasonable time period following a medical expense (connected expenses); ii. all or substantially all of the premiums paid under the plan relate to medical expenses that are eligible for the medical expense tax credit (METC); and iii. the plan meets all other conditions as outlined in paragraph 3 of Interpretation Bulletin IT-339R2, Meaning of private health services plan [1988 and subsequent taxation years]. ...

Moreover, Country A accounting standards do not require any restatement of CFA’s original financial statements with respect to the relevant taxation years in connection with the adjustment to CFA’s income under Country A’s tax law. ...

The broad wording of paragraph 6(1)(a) of the Act means that a taxable benefit may exist where there is any connection between a benefit and the particular office or employment. ...

Reasons: A complete analysis of all the relevant facts and circumstances is required in order to conclude on the application of subsection 84(2) to particular taxpayers. 2020 CALU CRA Roundtable – July 2020 Question 6 – Post-mortem Pipeline: Gradual Repayment of Note Background Previously, the CRA provided a number of favourable advance income tax rulings (“rulings”) in connection with post-mortem pipeline transactions. ...

The employment income earned by employees of Tribal Councils and First Nations may qualify for an exemption from tax under Guideline 4, which requires that: a) The employer is resident on a reserve; and b) The employer is: an Indian band which has a reserve, or a tribal council representing one or more Indian bands which have reserves; or an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves; and c) The duties of employment are in connection with the employer’s non-commercial activities carried on exclusively for the benefit of Indian’s who for the most part live on reserves. ...

Paragraph (a) of the definition provides that qualifying rent expense means a payment that is rent for the use of, or right to use, the qualifying property, including, among other things, and subject to the exclusions listed in subparagraph (a)(ii), gross rent, rent based on a percentage of sales, profit or a similar criterion, amounts required to be paid under a net lease by the eligible entity either to the lessor or a third party, as o base rent, o regular instalments of operating expenses, such as insurance, utilities and common area maintenance expenses, customarily charged to the lessee under a net lease, o property and similar taxes, including school and municipal taxes, and o regular instalments of other amounts payable to the lessor for services ancillary to the rental of real or immovable properties and customarily supplied or rendered in connection with the rental of real or immovable properties. ...