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The amount stipulated in the agreement is an amount considered reasonable by both parties to the agreement. ...

You have asked that we advise whether employees, who are within two years of qualifying for retirement benefits and who are provided with interim accommodation expenses and a set allowance to cover meals and travel rather than being required to relocate shortly before a scheduled retirement, are considered to be in receipt of a taxable benefit or whether such benefits will be exempted under the provisions of subsection 6(6) of the Act. ...

Subsection 103(1) of the Act applies where the principal reason for the agreement to share profits in a certain manner ".... may reasonably be considered to be the reduction or postponement of the tax that might otherwise have been or become payable under this Act, the share of each member of the partnership in the income or loss, as the case may be,........is the amount that is reasonable having regard to all the circumstances..... ...

" Returning the original cheques and requesting the Wheat Board to reissue the cheques at a later date would not in our view be considered a "special circumstance". ...

Saunders raised the issue of whether a subsection 105(1) benefit would be assessable to a parent where a trust pays the expenses of a child beneficiary normally considered to be parental obligations (i.e. food, shelter, clothing, etc; see pages 37:51 through 37:54). ...

The cost of the pool, which in this case mirrors exactly the amount which the client was reimbursed, is not considered a cost of the principal residence as these are two separate and distinct assets even if they may have been sold for one combined price. ...

Where an employer provides a mortgage interest subsidy to an employee, the benefit should be determined under subsection 80.4(1) of the Act if the mortgage can be considered to have been received by virtue of employment. ...

Principal Issues: Whether the passing of a by-law by an Indian band under section 83 of the Indian Act is sufficient to enable the band to be considered a municipality for the purposes of issuing receipts for charitable donations. ...

Subsection 7000(4) of the Regulations considers that, in circumstances in which the terms of the obligation include an option to extend the term of the obligation upon maturity, the renewal obligation will be considered, for the purposes of section 7000 of the Regulations, to be a continuation of the original obligation unless it could reasonably have been foreseen at the time of original issue that the renewal obligation would be issued at the then current rate of interest. ...

Paragraph 26 of Interpretation Bulletin IT-516R2, Tuition Tax Credit (IT-516R2) states that charges for use of library or laboratory facilities, whether identified separately or included as course or subject fees are considered eligible tuition fees. ...