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The comments in this letter are of general nature only and do not take into account considerations that might arise in connection with a specific transaction or event.  ...

" In addition, the definition of "qualifying educational program" specifically excludes a program of study taken in connection with, or as a part of, the duties of the student's employment, and during a period for which the student is receiving income for that employment. ...

Signed on August 21, 1998 XXXXXXXXXX Dear XXXXXXXXXX: The Honourable Herb Dhaliwal, Minister of National Revenue, has asked me to respond to your letter addressed to XXXXXXXXXX concerning the issuance of charitable donations receipts to sponsors in connection with a lottery. ...

If the employer were an Indian band or a tribal council, since your organization provides services to XXXXXXXXXX it is unlikely that Guideline 4 would apply since, under these circumstances, there is not sufficient connection to a reserve to provide an exemption. ...

The taxation of payments received by an employee in connection with a grievance has been the subject of several published tax cases, notably Vincent v. ...

Some of the more important conditions that an association or organization must comply with to qualify for exemption are as follows: (a)     it must not, in the opinion of the Minister, be a charity; (b)     it must be organized exclusively for social welfare, civic improvement, pleasure, recreation or any other purpose except profit; (c)     it must in fact be operated exclusively for one of the purposes mentioned in (b); and (d)     no part of its income may be paid, payable or otherwise made available for the personal benefit of any proprietor, member or shareholder, except in connection with the promotion of amateur athletics in Canada. ...

24 September 1993 Ministerial Letter 9325598 F- Same Sex Partner Coverage Under a PHSP Unedited CRA Tags 6(1)(a) XXXXXXXXXX Dear XXXXXXXXXX I am writing in response to your request for information in connection with XXXXXXXXXX the effects of income tax legislation on employee health plans that provide coverage for same-sex partners. ...

The employment duties of each particular Indian employee must be considered to determine if 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. ...

Unlike the examples on pages 7 and 8 of the Guidelines which describe situations where Guideline 4 is met, the connection between your organization's activities and Indians who for the most part live on reserves is not obvious. ...

An organization may be dedicated to the social, cultural or economic development of aboriginal people, but if those people are not Indians who for the most part live on reserves, there is not a sufficient connection to a reserve to exempt the employment income of its employees. ...