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Reasons: The terms of the settlement are considered to be consistent with the CRA's position as set out in paragraph 5 in IT-365R2. ... To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (i) dealt with in an earlier tax return of the Claimant or a related person; (ii) (ii) being considered by a tax services office or taxation center in connection with a previously filed return of the Claimant or a related person; (iii) (iii) under objection by the Claimant or a related person; (iv) (iv) before the Courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) (v) subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

December 7, 2005 SUMMERSIDE TAXATION CENTRE HEADQUARTERS Income Tax Rulings Attention: Wilma Bell Directorate Kimberly Duval (613) 599-6054 2005-015507 Taxation of Status Indian Employment Income This is in response to your memorandum of September 28, 2005, requesting our opinion as to whether employment income earned by XXXXXXXXXX, a status Indian employee, would be considered tax-exempt in the circumstances. Specifically, you have asked for our comments as to whether the employment income earned by XXXXXXXXXX for the XXXXXXXXXX and subsequent taxation years would be considered tax exempt based on the fact that she is a status Indian and her employment duties in the period related solely to Aboriginal people. ...

If an option of this nature is negotiable, can the value of the premium be considered a sound approximation of the value of the discount in calculating the FMV of the share? If an option of this nature is not negotiable, can the value of the premium on the put option of a share in the same sector be considered an acceptable approximation of the value of the discount in calculating the FMV of the share? ...

If the change in interest rates is considered a novation, there is a deemed disposition of the Note at fair market value. ... Justice Sexton in his reasons in General Electric Capital case considered the question of how to determine whether transactions have created a new obligation rather than simply modified an existing obligation and sought some guidance from the decision in Wiebe et al. v. ...

All these factors will be considered when determining whether several trusts will be considered one individual for the purposes of the Act. ...

There are two ways in which income can be situated on a reserve: 1. by a connecting factors analysis under which the amount is determined to be so connected to a reserve that it should be considered to be situated there, or 2. if the amount has been paid pursuant to a treaty with Her Majesty, section 90 of the Indian Act will deem it to be situated on a reserve for purposes of the section 87 tax exemption. ... It is important to note that for the Part II EI benefit included in income, paragraph 110(1)(g) of the Income Tax Act provides an offsetting deduction to the extent that the benefit can be considered to be tuition. ...

A property will not be considered to have been used for any purpose where it is new at the time that it is acquired but has been demonstrated for or tested by a prospective purchaser of that particular piece of equipment. ... However, a property that has been used regularly by the vendor for demonstration purposes is considered to have been used by the vendor. ...

While not necessarily conclusive, where a product provides for a death benefit or constitutes an annuity arrangement, it may be suggestive that it could be considered a life insurance policy for the purposes of the Act. ... Our comments will be based upon the assumption that the contract being considered is a "life insurance policy". ...

Subsection 130.1(6) of the Act sets out conditions all of which must be satisfied throughout a taxation year for a corporation to be considered a MIC. ... We have also opined that in other types of situations where property is used for commercial and residential activities and/or where the particular property is not zoned as being residential, no portion of a mortgage debt on such a property would be considered as being a debt secured by way of mortgage on a house or a housing project for the purpose of subsection 130.1(6) of the Act. ...

21 November 2017 CTF Roundtable Q. 16, 2017-0703891C6- Medical assistance in dying Unedited CRA Tags 118.2(2)(a) Principal Issues: Whether medical assistance in dying would be considered a medical service for the purpose of the medical expense tax credit (METC). ... In our view, the provision of medical assistance in dying as outlined in the Criminal Code, in conjunction with the requirements of the respective provincial and territorial health-related laws, rules and policies, as applicable, would be considered a medical service for the purpose of the METC. ...