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It asserts that the Applicant has not filed any evidence to indicate that she applied for the CRSB or any other related benefit and therefore that this alternative request should not be considered. [19] The document entitled “Confirming CERB, CRB, CRSB and CRCB Eligibility” [CRB Guidelines], sets out the procedure used by CRA officers to determine an applicant’s CRB eligibility, including information that is considered to be acceptable to support an application. [20] The CRB Guidelines state the following with respect to acceptable proof of self‑employment income: ● Invoice for services rendered, for self employed individuals or sub contractors. ...

In May of 1992, a dispute arose between Gurm and the Appellant, among other things, regarding the portion of the Total Commission to which Gurm was entitled: a) the Appellant considered that Gurm was entitled to 30% of the Total Commission, totalling $29,620.13; b) Gurm considered that he was entitled to 60% of the Total Commission totalling $59,240.25. 1 l. ...

There may be deducted in computing a taxpayer’s income for a taxation year such of the following amounts as are applicable: (b) an amount paid by the taxpayer in the year, pursuant to a decree, order or judgment of a competent tribunal or pursuant to a written agreement, as alimony or other allowance payable on a periodic basis for the maintenance of the recipient thereof, children of the marriage, or both the recipient and children of the marriage, if he was living apart from, and was separated pursuant to a divorce, judicial separation or written separation agreement from, his spouse or former spouse to whom he was required to make the payment at the time the payment was made and throughout the remainder of the year; (c) an amount paid by the taxpayer in the year, pursuant to an order of a competent tribunal, as an allowance payable on a periodic basis for the maintenance of the recipient thereof, children of the marriage, or both the recipient and children of the marriage, if he was living apart from his spouse or former spouse to whom he was required to make the payment at the time the payment was made and throughout the remainder of the year; Section 60.1 reads in part as follows: 60 1(1) Where a decree, order, judgment or written agreement described in paragraph 60(b) or (c), or any variation thereof, provides for the periodic payment of an amount by a taxpayer (a) to a person who is (1) the taxpayer’s spouse or former spouse... the amount or any part thereof, when paid, shall be deemed for the purpose of paragraphs 60(b) and (c) to have been paid to and received by that person. (2) For the purposes of paragraphs 60(b) and (c), the amount determined by the formula A- B where A is the total of all amounts each of which is an amount (other than an amount to which paragraph 60(b) or (c) otherwise applies) paid by a taxpayer in a taxation year, under a decree, order or judgment of a competent tribunal or under a written agreement, in respect of an expense... incurred in the year or the preceding taxation year for maintenance of a person who is (a) the taxpayer’s spouse or former spouse.... or for the maintenance of children in the person’s custody or both the person and those children if, at the time the expense was incurred and throughout the remainder of the year, the taxpayer was living separate and apart from that person, and B |not applicable] Shall, where the decree, order, judgment or written agreement, as the case may be, provides that this subsection and subsection 56.1(2) shall apply to any payment made thereunder, be deemed to be an amount paid by the taxpayer and received by that person as an allowance payable on a periodic basis. (3) For the purposes of this section and section 60, where a decree, order or judgment of a competent tribunal or a written agreement made at any time in a taxation year provides that an amount paid before that time and in the year or the preceding taxation year is to be considered to have been paid and received thereunder, the amount shall be deemed to have been paid thereunder. ... There was no clear stipulation in the agreement that the previous payments were to be considered as having been paid and received under the agreement pursuant to subsection 60.1(3) of the Act. ...

Issues (L2/R5142/T0/BT0) test_marked_paragraph_end (308) 1.043 1094_1139_1231 The issues in these appeals are: (1) Can the Appellant’s home be considered a “nursing home” for the purposes of paragraphs 11 8.2(2)(b) and (d) of the Income Tax Act (the "Act")? If the answer to number (1) is in the negative, then alternatively: (2) Can the Appellant’s home be considered an “other place” for the purposes of paragraph 118.2(2)(e) of the Act? ...

This case, says the appellant, is a conversion case, not a distribution case, and so it has no liability for contributions or premiums based on the due-backs. [29] I disagree. [30] In its reasons, the Tax Court considered each of the cases the appellant submitted to this Court, describing Canadian Pacific Ltd. v. Canada, [1986] 1 S.C.R. 678 [Canadian Pacific], as the leading decision. [31] Canadian Pacific considered whether gratuities paid to hotel employees were insurable earnings under the Unemployment Insurance Act, 1971, S. ...

Professor Brooks has, however, in summarizing some re-occurring factual patterns, elucidated factors to be considered, and I find his discussion generally helpful: supra, at pp. 256- 59. ... Traditionally, expenses that simply make the taxpayer available to the business are not considered business expenses since the taxpayer is expected to be available to the business as a quid pro quo for business income received. ...

Through the testimony of the two expert witnesses I learned not only what they considered was meant by the word “roadway”, but also how forest roads are built. ... On the basis of what “appropriate grading” should a surface course be considered to exist? ...

Analysis and Decision: I have considered carefully the submissions of both Appellants. ... M.N.R., 91 D.T.C. 331 [330], 1 considered the taxability of a lump sum amount paid by an employer to an employee who moved from one city to another at the employer’s request. ...

.), Judge Dussault in interpreting Bronfman Trust (supra) said “Secondly, for the purposes of the deduction provided for in paragraph 20(1)(c) of the Act, it has also been established in Bronfman Trust (supra) that what should be considered is not the purpose of the borrowing itself but rather the purpose for which the borrowed money was used.” ... This was a shortcoming of the agreement and may be reflective of the fact that possibly the deductibility of the interest was not considered by the drafters of the separation agreement and only became significant after the agreement was put into place. ...

There is no evidence before me that he or his brother even considered that there would be a profit in year one or any other year. ... Then in paragraph 12, he goes on and says: The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...