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You further indicate that the VCC could be considered as a resident of both Canada and Israel under the domestic tax laws of those countries and liable to taxation therein by reason of its domicile, residence, place of management or any other criterion of a similar nature. ... " As the VCC was incorporated in Canada, even if it were otherwise found to be resident in both Canada and Israel under paragraph 1 of Article IV of the Treaty, subparagraph 3(a) thereof would nevertheless prevail such that the VCC would be considered resident in Canada for the purposes of the Treaty. ...

You have also enquired whether the employer's recognition program would be considered a loyalty program as detailed in the Canada Revenue Agency (CRA) Guide T4130, Employers' Guide – Taxable Benefits and Allowances. ... Since the CRA gifts and awards policy only applies to non-cash gifts and awards, the merchandise received from the redemption of points under the employer recognition program will be considered a taxable benefit under paragraph 6(1)(a) of the Act and the fair market value of the merchandise must be reported on the employee's T4 slip in the year the points are redeemed. ...

Can two strata units be considered one residence for the purposes of the definition of a principal residence? ... We refer you to rulings document E 2009-0311301E5 which discusses a number of factors which could be considered to make a complete determination in this regard. ...

The definition of QSBCS in subsection 110.6(1) of the Act incorporates, inter alia, three main tests, as briefly discussed below, that must be met in order for the individual's shares to be considered as QSBCS for these purposes. 1) Small Business Corporation ("SBC") Test The first test, in paragraph (a) of the QSBCS definition, examines the use of the particular corporation's assets at the time the shares are sold (i.e., the "determination time") and requires that the shares must be the shares of a SBC at the determination time. ... If the particular corporation itself has sufficient eligible assets described in (i) above to meet the 50% Holding Period Asset Use Test in paragraph (c), then the more stringent 90% Holding Period Asset Use Test described in paragraph (d) of the definition of QSBCS would not have to be considered. ...

CRA Tags 5(1) 81(3) 6(1)(a) Principal Issues: Are gifts over $100 given to an elected official considered a taxable benefit? ... The reimbursement of meals consumed while conducting the employer's duties are not considered a taxable benefit. ...

They would also be considered benefits conferred by the corporation to the shareholder by virtue of subsection 15(1) and 56(2). ... As indicated in paragraph 7 of Interpretation Bulletin IT-335R2, "Indirect Payments", amounts paid by a corporation to another person may still be considered as a benefit conferred by a corporation on a shareholder by virtue of subsection 56(2) of the Act. ...

X were both considered to be non-residents of Canada for purposes of the Income Tax Act (the Act), and residents of Italy for purposes of the Canada-Italy Tax Treaty. ... Further, in the situation you describe, we are of the view that a subsection 70(5) deemed disposition of an interest in a home in Canada that was owned by a resident of Italy would be considered an "alienation of immovable property" for purposes of Article 13(1) of the Canada-Italy Tax Treaty, and therefore subject to tax in Canada. ...

For instance, the courts have held that a reimbursement of an employee's personal expense would generally represent a benefit except where it constitutes a remedy for an economic prejudice suffered by reason of his employment and have typically considered the following factors in determining whether a taxable benefit had been conferred: Whether the item under review provides the employee with an economic advantage If so, is this economic advantage measurable in monetary terms? ... However, as noted in the T4130 in the section entitled "Moving Expenses and Relocation Benefits", if an employer pays or reimburses moving costs that are not included in the list of non-taxable payments provided therein, the amounts are generally considered a taxable benefit to the employee. ...

Subsection 137(7) of the Act provides that notwithstanding any other provision of the Act, a credit union that would otherwise be a private corporation is not to be considered a private corporation except for the purposes of certain provisions which includes inter alia section 125 of the Act. ... If this amendment is enacted as proposed, a cooperative corporation will be considered a private corporation and possibly a CCPC for purposes of these rules. ...

" Generally, an award that an employer provides to an employee is considered a taxable benefit from employment and is included in employment income under paragraph 6(1)(a). ... It is a question of fact whether a particular award is considered connected to the recipient's employment. ...