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9 January 2004 Internal T.I. 2003-0031601I7 F- Air Miles:employés/employeurs-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) business air miles assumed to be used before personal air miles When a shareholder or employee uses the employee’s credit card both for company business purposes (expenses for which the employee is reimbursed) and for personal purposes, if the employee acquires goods for personal purposes using Air Miles points, should the shareholder or employee be considered to be using business Air Miles points (so that there is a taxable benefit) or personal Air Miles points (so that there is none) first? ...

It went on to note that it was a question of fact whether the property could qualify as real property is considered to be used in the course of the carrying on the business of farming in Canada under s. ...

28 January 2004 Internal T.I. 2003-0047701I7 F- Télétravail et indien inscrit-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 Indian teleworker exempted re duties performed on Reserve Regarding a Status Indian, employed by the Department of Indian and Northern Affairs Canada, who resides and works on a reserve under a telework arrangement, CCRA stated: While the employee is participating in the telework program described in the telework arrangement and until the telework arrangement is terminated, the duties of the employment performed by the employee at the employee’s work place on the reserve will be considered duties of the employment performed on a reserve for the purposes of the Guidelines. ...

We wish to point out that the exclusion in paragraph 74.5(12)(a) demonstrates that Parliament considered RRSP income, which is included under paragraph 56(1)(h), to be income from property. ...

The Directorate stated: [I]n light of the fact that Holdco is the policyholder, holder and beneficiary of A's life insurance policy, the payment of premiums by Holdco in respect of that policy should generally not be considered to be a benefit conferred by Holdco on A that would be described in subsection 15(1). ...

27 September 2004 External T.I. 2003-0048241E5- site reclamation costs-- summary under Paragraph 20(1)(m) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(m) no reserve if s. 9 inclusion Respecting whether the CRA would accept a reserve being deducted under s. 20(1)(m) in a situation similar to that considered in Deputy Minister of Revenue for Quebec v. ...

., before kindergarten for children in Quebec) should be considered to be child care expenses unless there is clear and conclusive evidence that the fees are educational expenses,” and also noted that “[f]ees charged for supervision during study sessions or other directed supervision activities could constitute child care fees if they are optional,” and that educational costs may include, for example, extracurricular activities and special schools. ...

B were not considered common-law partners prior to their marriage. In that case, if Ms. ...

The legal nature of the property is also an element to be considered when determining the number of housing units in the residence. ...

CCRA indicated that since the cost of the shares acquired by Holdco on exercise of the options was increased by the amount of the adjusted cost base of the options pursuant to s. 49(3)(b)(ii), only a portion of the safe income on hand that would otherwise be allocable (without the cost increase) to the acquired shares (as described in 1999-0011695) could reasonably be considered to be allocable to those shares since the effect of the cost increase was to reduce any unrealized capital gain on the acquired shares. ...