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The term "advantage" in respect of a political contribution is very broadly defined in proposed subsection 248(32) of the ITA to include the value, at the time the monetary contribution is made, of any property, service, compensation, use or other benefit that the taxpayer, or a person or partnership who does not deal with the taxpayer at arm's length, has received, obtained or enjoyed, or is entitled either immediately or in the future and either absolutely or contingently, to receive, obtain or enjoy, that is in consideration for or in gratitude for the monetary contribution, or in any other way is related to the monetary contribution. ...

When the plan represents (i) an undertaking by one person, (ii) to indemnify another person, (iii) for an agreed consideration, (iv) from a loss or liability in respect of an event, (v) the happening of which is uncertain, it will be considered to be in the nature of insurance. ...

In consideration of the Insurer making such payments, the Plaintiff settles his claims against the Defendants. ...

In determining whether an individual would, but for the existence of the employer, reasonably be regarded as an employee of another person or partnership, the CRA will take into consideration all the facts and circumstances including: the level of control the payer has over the individual; whether the individual provides his or her equipment; whether the individual can subcontract the work or hire assistants; the degree of financial risk taken by the individual; the degree of responsibility for investment and management assumed by the individual; the individual's opportunity for profit; whether the payer is the only source of funds from which the individual is remunerated or whether individual has a number of customers; and any other relevant factors including contracts and supporting documentation. ...

It took into consideration that the Act was based on the principles of self- assessment and self-reporting, and was of the view that the person required to self-assess and self-report would not be able to determine whether the amount received was taxable, until he or she has provided the tax authorities with its return of income and been advised whether the amount declared was taxable. ...

Where the amount reimbursed to a public office holder matches his or her actual costs for the annual maintenance or administration of the blind trust or blind management agreement, and the reimbursement flows through to the person actually paying such costs, being either the public office holder or the blind trust, no taxable benefit arises to the public office holder and no deduction of these reimbursed costs is permitted in computing the public office holder's income or the blind trust's income, nor is it taken into consideration in computing any gain or loss from the disposition of any property. 3. ...

In general terms, the amounts described in paragraphs (a) and (b) of the value for "A" will reflect 63% of the total of the corporation's "full rate taxable income" for each taxation year of the corporation ending after 2000 and before 2006, with certain modifications depending on the taxation year in question, determined before taking into consideration the specified future income tax consequences for the year. ...

While the residence status of an individual can only be determined on a case by case basis after taking into consideration all of the relevant facts, generally, unless an individual severs all significant residential ties with Canada upon leaving Canada, the individual will continue to be a factual resident of Canada and subject to Canadian tax on his or her worldwide income. ...

The first notes that it is bestowed "without expectation of return or compensation"; the second that it involves a transfer without "consideration"; and the third says that it is effected "gratuitously". ...

Moreover, the court-ordered payment to the Foundation would not be deductible as a charitable gift under section 110.1 of the Act, because in order to be deductible as a charitable gift there must be a voluntary transfer of property without valuable consideration (see for example, paragraph 3 of Interpretation Bulletin IT-110R3, Gifts and Official Donation Receipts). ...