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The Committee on Fiscal Affairs of the Organisation for Economic Co-operation and Development (OECD) is working on the issue of the treatment of stock options under tax treaties, and in connection with this work, released a second public discussion paper entitled "Cross-Border Income Tax Issues Arising From Employee Stock Option Plans". ...

These interest amounts are to be treated as employment income subject to the usual tax withholdings and remittances and when received, should be included on the employee's T4 Supplementary. ix) In connection with the foregoing comment, we note that paragraph XXXXXXXXXX of the Procedure section of the Policy Manual extract submitted to us refers to the "salary accrual period" in discussing interest but the Definition section in the same document refers to the "deferral period. ...

" In summary, unless the proposed biogas system is used in connection with an "eligible sewage treatment facility", the methane gas produced in an anaerobic digester from dairy cow manure would not appear to be an eligible fuel for the purposes of Class 43.1. ...

In general, an RCA is defined in subsection 248(1) of the Act, as a plan or arrangement under which contributions are made by an employer or former employer of a taxpayer, or by a person with whom the employer or former employer does not deal at arm's length, to another person in connection with benefits that are to be or may be received or enjoyed by any person on, after or in contemplation of any substantial change in the services rendered by the taxpayer, the retirement of the taxpayer or the loss of an office or employment of the taxpayer. ...

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. ...

If, in a particular situation, the employer is no longer the major supplier then the case to support a connection to the reserve would be weakened. ...

Company This is in reply to your letter of August 12, 2004, requesting our comments with respect to the income tax status of an employee who will be moving from Canada to the United States in connection with a transfer of employment. ...

November 16, 2004 Dear XXXXXXXXXX: Re: Small Business Deduction We are writing in reply to your email of June 18, 2004 requesting our views in connection with the eligibility of a corporation to claim the small business deduction under section 125 of the Income Tax Act (the "Act") in a situation where the corporation ("Aco") carries on a business of leasing property consisting of equipment and portable trailers to XXXXXXXXXX operators. ...

., 1980 DTC 6272 (FCA), discussed the meaning of "rentals" at page 6275: "The word "rental" is not a familiar one to use in connection with property rights of the kinds enumerated but I see no reason to think that when used in reference thereto it would connote characteristics different from those it has in its more familiar use in relation to tangible property. ...

A clearly marked emergency-response vehicle that is used in connection with or in the course of an individual's office or employment with a fire department or the police is not an automobile by virtue of paragraph (b.1) of the definition of automobile in subsection 248(1) of the Act. ...