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Francine Dupuis 2004-009551 Late filing penalty- T5013 We are writing in reply to your September 16, 2004 memorandum concerning the XXXXXXXXXX (the "Partnership") and the late filing penalty assessed in connection with its annual partnership information return. ...

Subparagraph 6(1)(b)(vii) of the Act provides an exception for "reasonable allowances for travel expenses (other than allowances for the use of a motor vehicle) received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling away from the municipality where the employer's establishment at which the employee ordinarily worked or to which the employee ordinarily reported was located, and the metropolitan area, if there is one, where that establishment was located, in the performance of the duties of the employee's office or employment". ...

In connection with the Arrears, you indicated to us in our telephone conversation on May 3, 2001 (Eisner/Bulger) that Individual A verbally advised you that the hearing was held in XXXXXXXXXX and that it was concluded that Individual A was not required to pay the Arrears to Individual B. ...

Principal Issues: For purposes of the standby charge calculation, is the distance between an employee's home and an employer's retail store and the distance between one of the employer's retail stores and the employee's home, considered personal or "in connection with or in the course of the taxpayer's office or employment"? ...

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. ...

An RCA is defined as a plan or arrangement under which contributions are made by an employer or former employer of a taxpayer to a custodian in connection with benefits that are to be, or may be, paid out 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. ...

Any revenue earned by the Association in connection with the Program appears to be in the form of royalties received from the Partner. ...

In a previous opinion, we had noted that the limited weight that an on reserve customer would otherwise carry as a connecting factor will not be recognized if it can reasonably be considered that one of the main purposes for the location of the customer on reserve is to serve as a connection between the fishermen's business and a reserve, by acting as an intermediary between the fishermen and the actual fish buyers who are located off reserve. ...

Scenarios 1 to 4 Although there may be some differences in each of the first 4 scenarios described by the taxpayer, the issue in each of the scenarios is whether trips to and from the normal worksite would be considered to have been in connection with or in the course of the taxpayer's office or employment or whether they would be considered personal travel. ...

In connection with your request, we note that your office is satisfied that the caregivers are independent contractors rather than employees. ...