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Clearly, the employer considered the payment to be in respect of salary, wages or other employment benefits because a T4 slip was issued for the amount paid, and the applicable statutory deductions for Employment Insurance premiums, and Canada Pension Plan contributions were withheld. ...

Reasons: To determine the cost of a property acquired by a beneficiary that is subject to taxation in Canada, the deceased would be considered to be a taxpayer. ...

If it is determined that an arrangement is not an RCA, the proper taxation of the arrangement would have to be considered. ...

For purposes of administering the provisions of the Act relating to the tuition tax credit, an individual's assertion that they will be pursuing a CPL, though perhaps evidence of intention, is not considered to constitute "proof". ...

Rather than viewing the income earned by the RRSP as a separate "element", the benefit should be considered as the mathematical result of the application of the "tracking" of the fair market value of pools of assets as discussed generally above. ...

Subsection 67.1(4) of the Act specifically provides that no amount paid or payable for travel on an airplane, train or bus is to be considered to be in respect of food, beverages or entertainment. ...

Paragraphs 5 to 9 of interpretation bulletin IT-75R3, Scholarships, Fellowships, Bursaries, Prizes and Research Grants, describe the CCRA's views on what has to be considered in distinguishing employment income from bursary income. ...

The central management and control of an organization is usually considered to be exercised by the group that performs the function of a board of directors of the organization. ...

Essentially, the taxpayer is considered to be only receiving re-payments of capital up until the time that the payments made under the policy exceed the purchase price of the annuity. ...

However, in circumstances where the payment can reasonably be regarded as being in recognition of long service or as compensation for loss of office, it is considered to be a retiring allowance. ...