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As further stated in paragraph 22 of IC-70-6R5, CCRA also provides, in writing, technical interpretations of specific provisions of the Act and accordingly, we offer the following general comments in connection with your request which we hope will be of assistance to you. ...

Reimbursements or awards for legal fees in connection with the collection or establishing a right to income from employment are included in income from an office or employment by virtue of paragraph 6(1)(j) of the Act. ...

This provision provides that the following types of costs, amongst others, do not qualify as CRCE: i) certain expenses in respect of overhead and management, ii) expenses relating to financing and interest, iii) certain expenses for the acquisition, or use of, land, including the grading, levelling or landscaping thereof, other than costs relating to: A) a temporary access road to the project, B) a right of access to the project site during the start-up phase, or C) clearing land as required to complete the project, iv) amounts paid to a non-resident person or a partnership which is not a Canadian partnership (other than costs relating to a test wind turbine), v) amounts that would otherwise be included in the capital cost of depreciable property, other than costs incurred: A) for a temporary access road to the project, B) for clearing land as required to complete the project, C) for process engineering for the project, or D) for a test wind turbine, vi) amounts that would otherwise be included in the capital cost of intangible property, other than costs incurred: A) for making a service connection to transmit electricity to a purchaser, B) for a temporary access road to the project, C) for a right of access to the project site during the start-up phase, D) for clearing land as required to complete the project, or E) for process engineering for the project, or vii) an amount for the acquisition of inventory or an expenditure for scientific research or experimental development. ...

It also requires that 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 that the duties of the employment are in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserve. ...

Cco has taken the position that the $800,000 purchase price for the Bco Shares should be allocated among Cco's various properties for the purposes of determining the fair market value of Cco's capital properties in connection with the application of s. 111(4)(c) of the Act. ...

It also requires that 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 that the duties of the employment are in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserve. ...

Although we are unable to provide an opinion in respect of the specific transactions described in your letter, we offer the following general comments in connection with your request which we hope are of assistance to you. ...

IT-63R5 explains what constitutes personal use of an employer provided motor vehicle at paragraph 5: In addition to what would obviously be considered use of a motor vehicle supplied by an employer that is not in connection with or in the course of the taxpayer's office or employment, i.e., personal use (e.g., vacation trips, personal shopping trips, etc.), such use includes travel between the employee's place of work and home, even though the employee may have to return to work after regular duty hours. ...

September 22, 2004 Dear XXXXXXXXXX: Re: Superficial Loss This is in response to your email of April 22, 2004 requesting our comments in connection with the application of the definition of "superficial loss" described in section 54 of the Income Tax Act (the Act) in the hypothetical situation described below. ...

You requested that such determination be made in connection with the following facts: a) Mr X is the sole shareholder of a Canadian operating company ("Opco"); b) Mr. ...