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Our Comments: An RCA is defined in subsection 248(1) of the Act as generally being an arrangement under which payments are made by an employer to a custodian in connection with benefits that are to be received by an employee on, 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, subject to certain listed exclusions. ...

"personal and living expense" shall include inter alia (i) the expenses of properties maintained by any person for the use or benefit of any taxpayer or any person connected with him by blood relationship, marriage or adoption and not maintained in connection with a business carried on bona fide for a profit and not maintained with a reasonable expectation of a profit. ...

However, we do not share your view that because telework arrangements must be initiated by an employee, the existence of one where 50% of duties must be carried out on reserve, automatically confirms that the main reason for the arrangement is to establish such a connection. ...

However, for the purposes of subparagraph 6(1)(b)(vii.1), subparagraph 6(1)(b)(x) of the Act deems 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 if it is not calculated solely by reference to the number of kilometres for which the vehicle was so used in the year. ...

To the best of your knowledge and the knowledge of the Employer, none of the issues involved in this ruling request is being considered by a tax services office or taxation centre in connection with an income tax return already filed, and none of the issues is under objection or appeal. ...

Our Comments Paragraph 110.7(1)(a) of the Act permits a deduction of an amount determined by multiplying a specified percentage (defined in subsection 110.7(2)) by the travel benefits received or enjoyed by the taxpayer or a member of the taxpayer’s household in connection with the taxpayer’s employment in a prescribed northern zone or a prescribed intermediate zone, to the extent that: a) the amount received or the value of the travel benefit does not exceed a prescribed amount (as defined in section 7304 of the Income Tax Regulations), is included in the taxpayer’s income and not otherwise deducted by the taxpayer in computing income for the year or any other taxation year, and is not included in any medical expense tax credit (subsection 118.2(1) of the Act); b) the travel expenses were incurred in respect of trips made in the year by the taxpayer or an individual who was a member of the taxpayer’s household during the period in which the taxpayer resided in the particular year; and c) the taxpayer or an individual who was a member of the taxpayer’s household is not entitled to a reimbursement or any form of assistance in respect of travel expenses to which (b) above applies. ...

Pursuant to paragraph 212(13.1)(a), a partnership is deemed to be a person resident in Canada for purposes of Part XIII in connection with the portion of an amount that it pays or credits to a non-resident person that is deductible in computing the partnership’s income or loss from a Canadian source. ...

A comment in the Technical Notes to paragraph 8502(d) of the Regulations states that a plan may provide for payment of all reasonable administrative, investment and similar expenses incurred in connection with the plan. ...

This view was reflected in the closing paragraph of the Document, wherein it was indicated that: It is our view, that the appropriate treatment including the application of paragraph 12(1)(g) and the comments in IT-373R to amounts received by a landowner in connection with the activities described above, will depend on the specific facts and circumstances as well as the purpose and objective of the particular transaction. ...

In connection with the enquiry, we requested a copy of the actual complaint from XXXXXXXXXX. ...