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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. ...

The individual performed substantially all of the duties of his or her employment (a) outside Canada; and (b) in connection with one or more activities described in subparagraph 122.3(1)(b)(i) or (ii) of the Act. 5. ...

Principal Issues: Tax treatment of transaction costs incurred by Purchaser in respect of aborted share or asset acquisition Position: Generally, the transaction costs incurred by Purchaser would be regarded as capital expenditures; it would be a question of fact whether these expenses would constitute eligible capital expenditures Reasons: The law XXXXXXXXXX 2002-015140 Gwen Watson March 5, 2003 Dear XXXXXXXXXX: Re: Transaction Costs- Aborted Acquisition This is in reply to your letter of June 28, 2002, wherein you requested our views regarding the tax treatment, under the Income Tax Act (Canada) (the "Act"), of certain fees incurred in connection with an aborted purchase of shares or assets. ...

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. ...

Generally, an individual's use of land in excess of 1/2 hectare in connection with a particular lifestyle does not, in and by itself, mean that the excess land is necessary for the use and enjoyment of the housing unit as a residence. ...

Guideline 4 requires a) that 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; and c) 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. ...

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 Indian who for the most part live on reserve. ...

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 Indian who for the most part live on reserve. ...

These guidelines are: 1. where substantially all the duties of employment are performed on a reserve; 2. where the Indian lives on a reserve and the employer is resident on a reserve; 3. where more than half the duties are performed on a reserve and either the Indian lives on a reserve or the employer is resident there; 4. where the employer is resident on a reserve, and 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, 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. ...

In our view, this provision does not contemplate the situation where an amount is included in the income of the employee/annuitant in connection with payment of a benefit in accordance with subsection 146(8) even if a benefit resulting from an office or employment pursuant to paragraph 7(1)(c) has already been included in his income. ...