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Specifically, the travel expenses must be reasonable in amount and have been incurred in connection with the transportation of a patient who is a taxpayer, his spouse or a dependant and in respect of only one individual who accompanied the patient. ...

(As you noted in our telephone conversation of July 13, 1995, we have previously concluded that the entitlement may be a concurrent one and can arise in connection with the negotiation of the employee's termination- see our memoranda of May 8, 1990 (900515), and October 28, 1993 (932607).) ...

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. ...

In the case of funds loaned to another party, the same argument holds-that is that a hope of earning income from some other source (i.e the shares) is too remote a connection to the non-interest bearing debt to say that the loan was incurred for the purpose of earning income from a business or property January 25, 1996 Appeals and Referrals Division HEADQUARTERS Lorraine Tremblay A. ...

Massicotte, CA, M.Fisc. (613) 590-1116 Attention: XXXXXXXXXX 2003-000790 Travelling Expenses This is in response to your memorandum of March 11, 2003, requesting our comments in connection with the deduction under paragraph 8(1)(h.1) of the Income Tax Act (the "Act") of motor vehicle expenses of a taxpayer employed as a XXXXXXXXXX worker in a specific situation. ...

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. ...

It also requires 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 that the duties of the employment be 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. ...

In our view, the connection between the payment and the sale of the business is relevant to the characterization of the payment. ...

Subsection 402(5) of the Regulations further provides that, for purposes of subsection 402(3) of the Regulations, gross revenue does not include interest on bonds, debentures or mortgages, dividends on shares of capital stock, or rentals or royalties from property that is not used in connection with the principal business operations of the corporation. ...

As requested, we have enclosed the documentation you provided to us in connection with your inquiry. ...