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On XXXXXXXXXX, the Board of Predco1 retained the services of a financial/investment advisor, XXXXXXXXXX, to obtain advice in connection with the proposed Business Combination with Predco2, XXXXXXXXXX. 8. ... On XXXXXXXXXX, Predco1 retained the services of a law firm, XXXXXXXXXX, to obtain legal advice in connection with the proposed Business Combination with Predco2, XXXXXXXXXX. 12. ... On XXXXXXXXXX, Predco2 retained the services of a law firm, XXXXXXXXXX, to obtain legal advice in connection with the proposed Business Combination with Predco1, XXXXXXXXXX. 19. ...

These payments did not have any connection to a reserve, except to the extent that the client was an Indian residing on a reserve. ... Further, should XXXXXXXXXX have expenses that he would like to claim with respect to off-reserve (taxable) income, he must provide documentation to support these amounts and their connection to that income and indicate that these expenses were not reimbursed. ...

However, if the legal fees were incurred by a taxpayer to establish a right to a promotion or a raise, or to seek financial compensation in connection with allegations of unlawful or wrongful acts by an employer, such amounts would not be deductible under paragraph 8(1)(b) of the Act. ... In these circumstances, and assuming the suit claimed some sort of monetary compensation attributable to the disputed period, it would be more proper to conclude that the legal fees were incurred by a taxpayer to establish a right to seek financial compensation in connection with allegations of unlawful or wrongful acts by an employer, which as noted above, would not be deductible. ...

Generally, GST paid or payable by an employer in connection with employee benefits provided by the employer would be deductible pursuant to the general rules of section 9 of the Act, unless the taxpayer makes an election under subsection 12(2.2) of the Act to exclude the amount of any ITC received from income which would otherwise be taxable pursuant to paragraph 12(1)(x) of the Act. ... It continues to be our view that we are not aware of any factors that would preclude an employer from deducting the GST/HST paid or payable (in the case of an employer using the cash method of reporting income) in connection with employee benefits provided by an employer. ...

Given that the definition in subsection 127(9) of the Act of "qualified property" for the purpose of the investment tax credit recognizes the possibility of a corporation carrying on a fishing business in connection with a commercial fishing licence held by the individual, is a fishing vessel property which can be transferred to a corporation under the provisions of subsection 85(1) of the Act? ... The reference in subparagraph (d)(iv) of the definition of qualified property in subsection 127(9) of the Act has no effect for the purposes of subsection 85(1) of the Act; rather the expanded definition permits an individual to claim an investment tax credit in respect of an eligible vessel notwithstanding that the vessel may be leased to a corporation controlled by that individual for the purpose of fishing in connection with a commercial fishing licence issued by the Government of Canada. ...

Subparagraphs 6(1)(b)(x) and (xi) of the Act deem an allowance received in a taxation year by an employee for the use of a motor vehicle in connection with, or in the course of, an office or employment not to be a reasonable allowance for the purposes of subparagraph 6(1)(b)(vii.1) of the Act when: (a)the allowance is not calculated solely by reference to the number of kilometres for which the vehicle was so used in the year, or (b)the employee receives an allowance for use of the vehicle and is reimbursed in whole or in part for expenses for the use of the vehicle in the year in connection with the office or employment except where the reimbursement is for supplementary business insurance or toll or ferry charges and the amount of the allowance is determined without reference to those reimbursed expenses. ...

Given that the definition in subsection 127(9) of the Act of "qualified property" for the purpose of the investment tax credit recognizes the possibility of a corporation carrying on a fishing business in connection with a commercial fishing licence held by the individual, is a fishing vessel property which can be transferred to a corporation under the provisions of subsection 85(1) of the Act? ... The reference in subparagraph (d)(iv) of the definition of qualified property in subsection 127(9) of the Act has no effect for the purposes of subsection 85(1) of the Act; rather the expanded definition permits an individual to claim an investment tax credit in respect of an eligible vessel notwithstanding that the vessel may be leased to a corporation controlled by that individual for the purpose of fishing in connection with a commercial fishing licence issued by the Government of Canada. ...

Please note that 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. ... The employment duties of XXXXXXXXXX employees would also have to be considered to determine if, as required under Guideline 4, they were 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. ...

Reasons FOR POSITION TAKEN: Owing to the fact that the author is seeking information in connection with completed transactions involving a specific taxpayer, our response was channelled through the local TSO (request initially forwarded to us by the TSO) and was limited to very general comments concerning subparagraph 20(1)(p)(ii)? ... Nevertheless, we offer the following general comments in connection with your request which we hope is of assistance to you. ...

Acts of kindness, friendship, forethought or goodwill might properly be described as benevolent.... where the word is used in connection with other words explanatory of its meaning, and indicating the intent of the donor to limit it to purposes strictly charitable, it has been held to synonymous with or equivalent to, "charitable". ... The definition of "retirement compensation arrangement" in subsection 248(1) of the Act include, subject to certain exclusions, "a plan or arrangement under which contributions (other than payments made to acquire an interest in a life insurance policy) are made by an employer or former employer of a taxpayer,... to another person or partnership (in this definition and in Part XI.3 referred to as the "custodian") in connection with benefits that are to be or may be received or enjoyed by any person on, after or in contemplation of, the retirement of the taxpayer". ...