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In general, the Department will not challenge the reasonableness of salaries and bonuses paid to the principal shareholders-managers of a corporation when (a)the general practice of the corporation is to distribute the profits of the company to its shareholders-managers in the form of bonuses or additional salaries; or (b)the company has adopted a policy of declaring bonuses to the shareholders to remunerate then for the profits the company has earned that are, in fact, attributable to the special know-how, connections, or entrepreneurial skills of the shareholders. ...

The individual subsequently commenced legal action against his or her solicitor with respect to the amount of the fees that were charged in connection with the damages claim. ...

According to the Labour Sponsored Venture Capital Corporations Act, 1992 (S.O. 1992, c. 18- the "Ontario Act") a labour sponsored investment fund corporation must have as its business: I.assisting the development of eligible businesses, creating, maintaining and protecting jobs a)by providing financial and managerial advice to eligible businesses b)and by providing capital to eligible businesses through the acquisition and holding of shares and qualifying debt obligations (defined as a debt obligation that, if secured, is secured solely by a floating charge or a debt obligation in respect of which a guarantee has been given) issued by eligible businesses that are corporations and (through) ownership interests of and qualifying debt obligations issued by eligible businesses that are Canadian partnerships II.incorporating and controlling such other corporations to provide services to the corporation in connection with the distribution of the corporation's shares or to provide financial, investment or managerial advice and expertise. ...

In addition, the above comments should in no way be construed as relating to any other tax issues in connection with participation in such plans. ...

In connection with the above requirements, the Department does not consider that a payment can be regarded as having been directly or indirectly received under a provincial program for the benefit of another person where the caregiver is receiving salary or wages from the employer. ...

In response to your question concerning employment expenses, we enclose Interpretation Bulletin IT-352R2 "Employees' Expenses Incurred in Performing the Duties of Office or Employment" which discusses the circumstances under which an employee may deduct reasonable costs incurred in connection with his or her home. ...

Briefly, Guideline 4 requires that a) the employer is resident on a reserve; b) 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; c) 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 reserves. ...

Briefly, Guideline 4 requires that a) the employer is resident on a reserve; b) 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; c) 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 reserves. ...

Briefly, Guideline 4 requires that a) the employer is resident on a reserve; b) 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; c) 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 reserves. ...

Accordingly, a plan which covers other types of expenses incurred in connection with an illness or accident such as homemaking services or tutorial services or which provides a daily allowance instead of a reimbursement will not be a private health services plan. ...