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Municipality or Metropolitan Area As also described in ITTN #40, in some situations, employer-provided allowances for items such as food or beverages in connection with an employee's travel within a municipality or a metropolitan area, can be excluded from the employee's income where: The amount is reasonable; The employer is the primary beneficiary of the allowance; and The amount does not seem to be an additional form of remuneration. ...

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. ...

You have asked for clarification of the meaning of the word "ordinarily" as used in connection with the deduction of employees' motor vehicle expenses under paragraph 8(1)(h.1) of the Act. ...

Further, the duties of the employment must be in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on a reserve. ...

However, travel expenses or motor vehicle expenses incurred in connection with travel from the employee's home to a job site and back home from a job site at the end of the day would not qualify for the deduction under paragraph 8(1)(h) or (h.1). ...

Position: The eligible amount of a monetary contribution for purposes of the proposed amendments to subsection 127(3) of the Income Tax Act would be the amount of the person's monetary contributions to the party in the year, less the fair market value of any advantages that the person or persons not dealing at arm's length with the person became entitled to receive or enjoy in connection with having made the monetary contributions. ...

Nevertheless, we offer the following comments in connection with your request. ...

In order for a motor vehicle allowance to be exempt from tax, subparagraph 6(1)(b)(x) of the Act states that it must be based "solely on the number of kilometres for which the vehicle is used in connection with or in the course 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. ...

If you have a proposed transaction involving a potential SIFT partnership, we would be prepared to review the terms and conditions relating the partnership and the mutual fund trust that holds a significant interest in the partnership in connection with a request for an advance income tax ruling in order to provide a definite opinion on the tax consequences that you wish us to confirm. ...