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Where a house is made available for the personal use of shareholders in their capacity as shareholders, a benefit under subsection 15(1) of the Act is generally considered to have been conferred on the shareholder. ...

As such, the property would still be held by Trustco in a trust which would still be considered the original RRSP trust. ...

A taxation year is considered to be statute-barred after the normal reassessment period. ...

If the primary purpose of the training allowance is to provide financial assistance to students in need in order to further their education, and amounts are not paid in conjunction with regular social assistance, then the amounts paid will be considered bursaries and will be included in income pursuant to paragraph 56(1)(n) of the Act. ...

Whether, and to what extent, such stock option benefit can be considered to relate to the duties of an office or employment performed in Canada is a factual determination which must be made on the basis of the facts in any particular case. ...

It is the Department's position that exempt income is not considered earned income for RRSP purposes, however after February 14, 1998, it is no longer exempt. ...

In our view, the training assistance received by the individuals described above, under Part II of the EI Act will normally be considered allowances or benefits for the purposes of section 118.6 of the Act and the recipients would not be eligible for the education tax credit. ...

The type of expenses in issue here have never been considered by any other Court.... ...

We agree that a foreign exchange gain in respect of foreign currency used by the taxpayer in its day-to-day operations would be considered to be on account of income. ...

However, the Department's practice of accepting amended T2013's should also be considered. ...