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You indicated that the steel tanks and oak barrels are not property that would be considered as a building or other structure (or part thereof) described in class 1 of Schedule II of Income Tax Regulations (the "Regulations") and on that basis you would like to know if the taxpayer's capital cost of such property would be included in class 29 of Schedule II of the Regulations for CCA purposes. ... The activities of breaking bulk and repackaging for subsequent resale where there is a systematic procedure to make a product more marketable are generally considered to be processing. ...

8 January 2015 Internal T.I. 2014-0542451I7- Indian Employment Income- Volunteer Firefighters CRA Tags 81(1)(a) Indian Act 87(1)(b) Principal Issues: Is the employment income of an Indian, who works as a volunteer firefighter in remote areas, considered tax exempt pursuant to paragraph 81(1)(a) of the Income Tax Act and section 87 of the Indian Act? ... The courts have determined that for the purposes of section 87 of the Indian Act, employment income is considered personal property. ...

A number of court cases have considered how an activity undertaken for profit is distinguished from a personal endeavour for income tax purposes. ... " Consequently, if it is clear that a personal endeavour or hobby is pursued in a sufficiently commercial and businesslike way, it can be considered to be a business activity, which is a source of income under the Act. ...

A reasonable time will usually not be considered to extend beyond the end of the taxation year following the year in which the debt or obligation became payable by the trust. However, where subsection 104(18) applies with respect to the income of a trust in which a minor beneficiary has a vested interest, a reasonable time will usually not be considered to extend beyond the end of the taxation year following the year in which the child reaches the age of majority. ...

If such income received by the organization is not incidental, the organization may be considered to have a profit purpose and may be considered to have made income available for the personal benefit of its members, particularly when the amounts are received from non-members. ...

Is the income paid to an employee considered to be employment income when the employee agrees to display the employer's corporate logo on his or her own automobile? ... In the case of an employee who receives the amount for publicity, would the allowance received for the employee's use of his or her motor vehicle still be considered reasonable? ...

The situation described in your email is similar to a case considered by the Tax Court of Canada. ... Her Majesty the Queen, 2011 TCC 192, the issue of when advance commissions must be included in income was considered again by the Tax Court. ...

Generally, a plan will be considered to be a superannuation or pension plan where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodic payment on or after the employee's retirement. ... However, where a lump-sum payment does not represent a settlement of future entitlements under the pension plan, such as a payment of periodic pension payments in arrears or a payment of a retroactive adjustment on the periodic pension payments, that lump-sum payment will be considered part of the series of periodic payments and therefore will not be eligible for the deduction. ...

Position: No Reasons: It is our view that in applying proposed subsection 5907(2.03) of the Regulations in respect of the active business of a foreign affiliate for the particular taxation year referred to in that subsection, any deduction claimed by the foreign affiliate in computing its earnings or loss from that business, in any taxation year of the affiliate that began on or before the commencement of the particular taxation year and for which its earnings or loss from that business had been determined under subparagraph (a)(i) or (ii) of the definition "earnings" in subsection 5907(1) of the Regulations, would be considered to have been actually claimed under the Act and to be within the maximum amount deductible. ... Our comments It is our view that in applying proposed subsection 5907(2.03) of the Regulations in respect of the active business of a foreign affiliate for the particular taxation year referred to in that subsection, any deduction claimed by the affiliate in computing its earnings or loss from that business, in any taxation year of the affiliate that began on or before the commencement of the particular taxation year and for which the earnings or loss from that business had been determined under subparagraph (a)(i) or (ii) of the definition "earnings" in subsection 5907(1) of the Regulations, would be considered to have been actually claimed under the Act and to be within the maximum amount deductible. ...

For example, maintaining reasonable operating reserves or bank accounts required for ordinary operations will generally be considered to be an activity undertaken to meet the not-for-profit objectives of an organization. ... Similarly, if the XXXXXXXXXX is delaying distributions to Members in order to increase funds available for investing, it could be considered to be operating for a profit purpose. ...