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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. ... For the employees, the connection to a reserve is that the employer is resident on reserve.... ... Answer #7 b) As discussed in question #1, in order for the employment income of a status Indian to be exempt under Guideline 4, all of the following elements must be met: 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. ...

(i) In connection with a conversion hereunder, rights or securities of, or interests in, the other entity which is to be converted to a domestic limited partnership may be exchanged for or converted into cash, property, rights or securities of, or interests in, such domestic limited partnership or, in addition to or in lieu thereof, may be exchanged for or converted into cash, property, rights or securities of, or interests in, another domestic limited partnership or other entity or may be cancelled. ... (d) In connection with a conversion of a domestic limited liability company to another entity or business form pursuant to this section, rights or securities of or interests in the domestic limited liability company which is to be converted may be exchanged for or converted into cash, property, rights or securities of or interests in the entity or business form into which the domestic limited liability company is being converted or, in addition to or in lieu thereof, may be exchanged for or converted into cash, property, rights or securities of or interests in another entity or business form or may be cancelled. ...

Guideline 4 exempts all of the employment income of an Indian if the employer is resident on a reserve, the employer is an Indian band or tribal council, 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 Folster, there was a historical connection between the services provided off-reserve and the reserve, and the relocation was involuntary. ...

Second, the amount must be "received in connection with the taxpayer's enrolment in an educational program in respect of which an amount may be deducted under subsection 118.6(2)"- that is, the individual must qualify for an education tax credit that is connected to an educational program that is connected to the amount. ... However, in our view, in many or most cases, the connection between the compensation received by an Academic PDF (which has been referred to many times by universities, academics and postdoctoral fellows alike as "salary"), and an educational program, will be so slight as to be insufficient to warrant the application of the full scholarship exemption. ...

The Courts have referred to several definitions of goodwill, two of which are: (a) "Goodwill is the whole advantage, whatever it may be, of the reputation and connection of the firm which may have been built up by years of honest work or gained by lavish expenditures of money". (b) It is "the privilege, granted by the seller of a business to the purchaser, of trading as his recognized successor; the possession of a ready-formed `connection' of customers, considered as an element in the saleable value of a business, additional to the value of the plant, stock-in-trade, book debts, etc. ...

The employees of the Corporation Guideline 4 of the Indian Act Exemption for Employment Income Guidelines (the "Guidelines") requires a) that the employer be resident on a reserve; b) that the employer be 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. ... In addition, to determine whether Guideline 4 applies to a particular Indian employee, the employment duties of the Indian employee have to be considered, in order to establish whether they 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. ...

This is evident from the various dictionary definitions of the word "royalty" when used in connection with a sum payable. ...

.- there was no Service Contract and the fee charged to Canco was equal to the amount of remuneration paid to the US Employee in respect of employment exercised in Canada in connection with the services. ...

In the case you described, if the licence agreement with the Board is cancelled in connection with the discontinuance of the childcare business, this would result in a disposition of the licence for purposes of determining whether a terminal loss may be claimed. ...

Although we are unable to provide an opinion in respect of the specific transactions described in your letter, we offer the following general comments in connection with your request which we hope are of assistance to you. ...