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  [19]         Thus, to be considered an allowance, there must be an agreement between the supplier and the reseller that the payment in question be made for the promotion of the product, or that the supplier allow a credit against or discount on the price of the product ...

When he considered these expenses and those which he incurred from being a student, he ought to have known that the business expense of $50,740.30 which he reported on his income tax return was incorrect. ...

There is no independent evidence of donative intent on the part of the Appellant, apart from his evidence that he would not have paid the amounts if they could not be considered charitable donations to the hospital. ...

  [29]         It remains to be considered whether referrals and collaboration by a licensed psychologist are sufficient to satisfy section 7. ...

There are many cases in which the matter has been considered both in this court and the Federal Court of Appeal. ...

Factors-- For the purposes of paragraph (h) of the definition “eligible individual” in section 122.6 of the Act, the following factors are to be considered in determining what constitutes care and upbringing of a qualified dependant: (a) the supervision of the daily activities and needs of the qualified dependant; (b) the maintenance of a secure environment in which the qualified dependant resides; (c) the arrangement of, and transportation to, medical care at regular intervals and as required for the qualified dependant; (d) the arrangement of, participation in, and transportation to, educational, recreational, athletic or similar activities in respect of the qualified dependant; (e) the attendance to the needs of the qualified dependant when the qualified dependant is ill or otherwise in need of the attendance of another person; (f) the attendance to the hygienic needs of the qualified dependant on a regular basis; (g) the provision, generally, of guidance and companionship to the qualified dependant; and (h) the existence of a court order in respect of the qualified dependant that is valid in the jurisdiction in which the qualified dependant resides. [22]         It is my view that the Appellant provided insufficient evidence to establish that she primarily fulfilled the responsibility for the care and upbringing of the twins either 30% or 50% of the time during the disputed period. ...

Analysis   [9]              There are some important definitions to be familiar with, all of which are found in section 122.6 of the Income Tax Act (the " Act "):   …   " eligible individual " in respect of a  qualified dependant  at any time means a  person  who at that time   (a)        resides with the  qualified dependant,   (b)                is a parent of the  qualified dependant  who   (i)                  is the parent who primarily fulfils the responsibility for the care and upbringing of the  qualified dependant  and who is not a  shared-custody parent  in respect of the  qualified dependant, or   (ii)        is a  shared-custody parent  in respect of the  qualified dependant, (c)                 is resident in Canada or, where the  person  is the  cohabiting spouse or common-law partner  of a  person  who is deemed under subsection  250(1)  to be resident in Canada throughout the taxation year that includes that time, was resident in Canada in any preceding taxation year,   (d)                is not described in paragraph  149(1)(a)  or  149(1)(b), and     (e)                 is, or whose  cohabiting spouse or common-law partner  is, a Canadian citizen or a  person  who   (i)         is a permanent resident within the meaning of subsection  2(1)  of the Immigration and Refugee Protection Act,   (ii)        is a temporary resident within the meaning of the Immigration and Refugee Protection Act, who was resident in Canada throughout the 18 month period preceding that time, or   (iii)       is a protected  person  within the meaning of the Immigration and Refugee Protection Act,   (iv)       was determined before that time to be a member of a class defined in the Humanitarian Designated Classes Regulations made under the Immigration Act,   and for the purposes of this definition,   (f)        where the  qualified dependant  resides with the dependant’s female parent, the parent who primarily fulfils the responsibility for the care and upbringing of the  qualified dependant  is presumed to be the female parent,   (g)        the presumption referred to in paragraph  122.6   eligible individual  (f) does not apply in  prescribed  circumstances, and   (h)        prescribed  factors shall be considered in determining what constitutes care and upbringing;   …   " qualified dependant " at any time means a   person   who at that time   (a)        has not attained the age of 18 years,   (b)        is not a  person  in respect of whom an  amount  was deducted under paragraph  (a)  of the description of B in subsection  118(1)  in computing the tax payable under this Part by the  person ’s spouse or  common-law partner  for the  base taxation year  in relation to the month that includes that time, and   (c)        is not a  person  in respect of whom a special allowance under the Children’s Special Allowances Act is payable for the month that includes that time;               …   " shared-custody parent " in respect of a qualified dependent at a particular time means, where the presumption referred to in paragraph (f) of the definition " eligible individual " does not apply in respect of the  qualified dependant, an  individual  who is one of the two parents of the  qualified dependant  who (a)        are not at that time cohabitating spouses or  common-law partner s of each other, (b)        reside with the  qualified dependant  on an equal or near equal basis, and (c)        primarily fulfil the responsibility for the care and upbringing of the  qualified dependant  when residing with the  qualified dependant, as determined in consideration of  prescribed  factors ...

It reads:   eligible individual in respect of a  qualified dependant  at any time means a  person  who at that time   (a)        resides with the  qualified dependant,   (b)        is a parent of the  qualified dependant  who   (i)         is the parent who primarily fulfils the responsibility for the care and upbringing of the  qualified dependant  and who is not a  shared-custody parent  in respect of the  qualified dependant, or   (ii)        is a  shared-custody parent  in respect of the  qualified dependant,   (c)        is resident in Canada or, where the  person  is the  cohabiting spouse or common-law partner  of a  person  who is deemed under subsection  250(1)  to be resident in Canada throughout the taxation year that includes that time, was resident in Canada in any preceding taxation year,   (d)       is not described in paragraph  149(1)(a)  or  149(1)(b), and   (e)        is, or whose  cohabiting spouse or common-law partner  is, a Canadian citizen or a  person  who   (i)                  is a permanent resident within the meaning of subsection  2(1)  of the Immigration and Refugee Protection Act,   (ii)        is a temporary resident within the meaning of the Immigration and Refugee Protection Act, who was resident in Canada throughout the 18 month period preceding that time, or   (iii)       is a protected  person  within the meaning of the Immigration and Refugee Protection Act,   (iv)       was determined before that time to be a member of a class defined in the Humanitarian Designated Classes Regulations made under the Immigration Act,   and for the purposes of this definition,   (f)        where the  qualified dependant  resides with the dependant’s female parent, the parent who primarily fulfils the responsibility for the care and upbringing of the  qualified dependant  is presumed to be the female parent,   (g)        the presumption referred to in paragraph  122.6   eligible individual  (f) does not apply in  prescribed  circumstances, and   (h)        prescribed  factors shall be considered in determining what constitutes care and upbringing;   [14]         Note that paragraph (f) in that definition is a presumption in favour of Ms.  ...

Benny considered the additional expenses claimed as clearly not reasonable in the circumstances ...

The Appellant relied specifically on the following paragraph: Income allocated pursuant to subsection 96(1.1) of the Act is business income but for the purposes of the CPP provision is not considered to be from a business carried on by the retired partner and consequently such a partner is not required to contribute to CPP solely as result of receiving such income. [14]         Canada Revenue Agency (“CRA”) advance rulings, such as this, are given in response to specific questions from a taxpayer. ...