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Pursuant to paragraph 118.2(2)(a) of the Act, an amount is considered to qualify as a medical expense for the purposes of the METC if it is paid to a medical practitioner, dentist or nurse or a public or licensed private hospital in respect of medical or dental services. ... In our view, a weight-loss program would be considered a medical service when the program is offered to an individual for therapeutic or rehabilitative reasons. ...

While the determination of what is considered a reasonable reserve can only be made after considering all of the facts and circumstances surrounding a particular situation, where subsection 20(6) of the Act is not applicable, in our view a reasonable reserve would represent the amount of the taxpayer's outstanding gift certificates at the end of the year less a percentage for gift certificates which (on the basis of past experience) will never be redeemed by their holders. ... While a mixed question of fact and law that can only be determined once all the relevant information has been considered, we are inclined to agree with your view that Aco's computation of income or profit for income tax purposes in the above-described circumstances is consistent with the rules in the Act. ...

Subparagraph 6(1)(a)(i) of the ITA indicates that contributions paid to a health insurance plan are not considered as a taxable benefit for employees. ... Question for the CRA Could reimbursement of medical expenses by the employer be considered non-taxable on the basis of the paragraphs mentioned above or on any other basis? ...

You always considered the house to belong to your sister and her family, although the legal title and mortgage are in your name. 6. ... A house is normally considered a capital property. However, a disposition does generally not occur for tax purposes if there is a transfer of title that is not accompanied by the transfer of beneficial ownership (paragraph (e) of the definition of "disposition" in subsection 248(1) of the Act). ...

One of the conditions that must be met for a real property of an individual to be considered a QFP as defined in subsection 110.6(1) of the Act is that the property, inter alia, must have been used principally in the course of carrying on the business of farming in Canada. Pursuant to subsection 110.6(1.3) of the Act, a property owned by an individual will not be considered to have been used in the course of carrying on the business of farming in Canada unless it has been owned by eligible owners referred to in paragraph 110.6(1.3)(a) of the Act, during a continuous eligible ownership period which is "throughout the period of at least 24 months immediately preceding that time" (i.e., time of disposition) and, in the case you described, the property is used in a farming business during such period as required by subparagraph 110.6(1.3)(b)(i). ...

Specifically you are inquiring whether this amount will be considered on account of income or capital. ... However, as indicated in paragraph 6 of IT 346-R, if a taxpayer does not undertake transactions in commodities in circumstances described in paragraphs 3, 4 or 5 of IT-346R, the taxpayer may be considered a speculator. ...

However, with respect to siblings, unless the facts indicate otherwise, generally one sibling would not be considered to have influence over another. In addition to the general factors described above, the composition of the board of directors and the control of day-to-day management and operation of the business would be considered. ...

The Partnership is considered to be a partnership for the purposes of the Act. ... The partnership is treated as if it were a separate person resident in Canada and its taxation year is considered to be its fiscal period. ...

Very generally speaking, where a CCPC earns income that would otherwise be considered as income from an active business from the provision of property or services to another private corporation and it (or one of its shareholders) or a person who does not deal at arm’s length with the CCPC (or one of its shareholders) holds a direct or indirect interest in that other private corporation, such income would not be considered as being eligible for the SBD unless one of the following conditions is met: all or substantially all of the CCPC’s income for the year from an active business is from the provision of services or property to persons (other than that private corporation) with which the CCPC deals at arm’s length, or partnerships with which the CCPC deals at arm’s length, other than a partnership in which a person that does not deal at arm’s length with the CCPC holds a direct or indirect interest; or the particular private corporation described above is able to (and does) assign all or a portion of its business limit to the CCPC under subsection 125(3.2). ...

Whether an amount is considered to be interest is a question of fact. ... It is our view that the cash back amount would not be considered to be interest. ...