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The compensation and reimbursement of an executor for time expended and costs incurred in connection with the administration of an estate are questions of fact and trust/estate administration law. ... Fees earned by a taxpayer for acting in the capacity of executor in the course of business form part of the business income of the taxpayer, and expenses incurred in this connection are deductible in the usual way in computing such income, to the extent they are not recoverable from the funds of the estate. ...

The deduction is generally limited to travel benefits or expenses in respect of trips made for the purpose of obtaining necessary medical services not available locally or with respect to travel benefits or expenses in connection with not more than two other trips per year. Paragraph 110.7(1)(a) of the Act refers, in part, to "an amount received, or the value of the benefit received or enjoyed, in the year by the taxpayer… in respect of travel expenses incurred by the taxpayer…" It is the view of the Canada Revenue Agency ("CRA") that there must be a connection between the actual travel expenses incurred by a taxpayer or a member of the taxpayer's household and the amounts paid by the taxpayer's employer to defray those costs, in order for the amounts to be "...in respect of travel expenses incurred by the taxpayer... ...

Upon the occurrence of an event of default, which would be limited to the insolvency or bankruptcy of a taxable Canadian corporation (“Canco”), the notes would automatically rank equally with preferred stock with respect to any amounts due in connection with such events. Upon any distribution of Canco’s assets to creditors in connection with an insolvency, bankruptcy or similar proceeding, all principal of, and premium, if any, and interest due or to become due on all other indebtedness of Canco must be paid in full before holders of the notes are entitled to receive any payment from such distribution. ...

Damages received in connection with a loss of employment clearly fall within the definition of a retiring allowance and consequently are taxable by virtue of subparagraph 56(1)(a)(ii) of the Act and subject to income tax withholding under paragraph 153(1)(c) of the Act. ... It is well established that the phrase “in respect of, in the course of, or by virtue of an office or employment” means that there need only be a small connection between a benefit and the employment in order to trigger the operation of paragraph 6(1)(a). ...

An individual, who is resident in Canada, is entitled to claim the OETC for qualifying income from employment in circumstances where the individual: (a) was employed by a specified employer (see definition below), other than for the performance of services under a prescribed international development assistance program of the Government of Canada; (b) was employed in connection with a contract (or for the purpose of obtaining such a contract) under which the specified employer carried on business outside Canada with respect to the exploration for or exploitation of petroleum, natural gas, minerals or other similar resources, with respect to any construction, installation, agricultural or engineering project or with respect to an activity performed under contract with the United Nations; and (c) performed all or substantially all the employment duties (done in connection with a contract described in (b) above) outside Canada. ...

12 January 2012 External T.I. 2011-0415991E5- OETC Eligibility & evacuation from foreign country Unedited CRA Tags 122.3 Principal Issues: Whether employees otherwise qualify for OETC pursuant to 122.3(1) when evacuated back to Canada during the qualifying period when they are teleworknig in connection with the foreign worksite from a location in Canada, or not working in Canada but "on call" to return to the foreign worksite at the request of the employer. ... In addition, whereas a particular activity may be performed in connection with an employment contract with an employer who carries on business outside of Canada, for purposes of this determination the CRA is generally of the view that the physical location of an employee performing an employment activity is of importance in determining where employment duties are performed inside. ...

For years prior to 2004, the former definition of a QEP in the Act excluded any program taken by a student: (i) during a period in respect of which the student receives income from an office or employment, and (ii) in connection with, or as part of the duties of, that office or employment. ... This means that provided all other requirements are met, a course or program taken by an individual in connection with his or her employment and during which time the individual received income from that employment is a QEP eligible for the education tax credit. ...

A TFSA trust that engages in option writing strategies that are speculative in nature may be considered to be carrying on a business and thus taxable on any premiums or other income earned in connection such activities. ... It is common practice for brokerage firms to impose margin requirements in connection with various options strategies. ...

Position: Inconclusive Reasons: The employer has not issued a T626, and we are not able to determine whether his duties of employment are in connection with a contract under which the specified employer carried on business outside Canada. ... One of the conditions for claiming the credit is that for a qualifying period you must have performed all or substantially all of your duties of employment outside Canada in connection with a contract under which your employer carried on business outside Canada. ...

An MHC, in this regard, means a land lease community arrangement under which a trust owns land and a supporting infrastructure, including utility connections, streets, lighting, driveways, common area amenities and other capital improvements, and tenants own mobile units that are their own homes situated on the lots that have been leased from the trust. ... Notably, "rent from real or immovable properties" is defined to include both rent for the use of real or immovable properties and payments 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. ...