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A new principal residence was purchased at the new work location and various moving expenses were incurred in connection with the move. ... For more information on what eligible moving expenses a taxpayer is allowed to deduct in connection with an eligible relocation, including limitations on how much the taxpayer can deduct from income in a particular year with respect to the relocation, please refer to Interpretation Bulletin IT-178R3 (Consolidated), Moving Expenses, and Form T1-M, Moving Expenses Deduction. ...

Paragraph 122.3(1)(b) requires that for the qualifying period "all or substantially all" of the duties of the individual's employment must be performed outside Canada in connection with a contract under which the employer carried on business outside Canada with respect to a qualifying activity. ... During a period of absence from a work location outside Canada, an employee may take sick time and still remain eligible for the OETC, provided that throughout the qualifying period substantially all of the employment duties are performed outside Canada in connection with a contract under which the employer carried on business outside Canada with respect to a qualifying activity. ...

However, as it may pertain to the situation described in your letter, subparagraph 6(1)(b)(v) of the Act excludes from income "reasonable allowances for travel expenses received by an employee from the employee's employer in respect of a period when the employee was employed in connection with the selling of property or negotiating of contracts for the employee's employer". For the purposes of subparagraph 6(1)(b)(v) of the Act, subparagraph 6(1)(b)(x) of the Act deems a motor vehicle allowance not to be reasonable if it is not based solely on the number of kilometres for which the vehicle is used in connection with or in the course of performing the duties of employment. ...

A reasonable per-kilometre allowance received by an employee for the use of his or her personal motor vehicle in connection with the duties of employment is generally excluded from employment income by virtue of paragraph 6(1)(b) of the Act. Subparagraph 6(1)(b)(vii.1) of the Act, for example, excludes "reasonable allowances for the use of a motor vehicle received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling in the performance of the duties of the office or employment". ...

The broad wording of this provision means that a taxable benefit may exist where there is any connection between the particular payment or benefit and the particular office or employment. It is our view that a lump sum payment such as the one made to the Employee in this case would be made in connection with his employment such that paragraph 6(1)(a) would apply. ...

Paragraph 122.3(1)(b) requires that for the qualifying period "all or substantially all" of the duties of the individual's employment must be performed outside Canada in connection with a contract under which the specified employer carried on business outside of Canada with respect to a qualifying activity. ... During a period of absence from a work location outside Canada, an employee may take sick time and still remain eligible for the OETC, provided that throughout the qualifying period substantially all of the employment duties are performed outside Canada in connection with a contract under which the employer carried on business outside Canada with respect to a qualifying activity. ...

Any deduction available to the individual under subsection 20(11) or 20(12) for foreign taxes paid by that individual in respect of the income attributed to that individual under subsection 75(2) is subject to the test imposed by the preamble to subsection 20(1) which provides that: "..there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto:" While it is evident from the wording of subsection 20(1) that there must be a clear connection between the amount sought to be deducted under either subsection 20(11) or 20(12) and the foreign taxes paid, it seems clear that this connection would be met in the situation you describe. ...

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. ...

While it remains a question of fact as to whether the payment you received would be considered as a retiring allowance or employment income, the legal fees that you incurred in connection with establishing a right to receive this payment would appear to be deductible either under paragraph 8(1)(b) of the Act, or paragraph 60(o.1) of the Act, as described above. ... We understand that you have also incurred legal fees in connection with a separate defamation lawsuit against a third party. ...

Where an individual is otherwise required to include an amount in income under paragraph 56(1)(n), if the amount is received in connection with an educational program that is eligible for the education tax credit under section 118.6 of the Act a full exemption will be available for such qualifying amounts that are received in 2006 and in subsequent taxation years pursuant to subsection 56(3). ... Finally, we would like to note that the 2007 Federal Budget proposes, for the 2007 and subsequent taxation years, that the total of all amounts received by an individual on account of scholarships and bursaries in connection with that individual's enrolment in an elementary or secondary school will also be excluded from that individual's income. ...