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Based on this function, it appears that a cast would be considered “a brace for a limb”, and as such would qualify as an eligible medical expense for the purposes of paragraph 118.2(2)(i) of the Act. ...

Therefore, the assistance under the potential relief measure program would likely be considered a social assistance payment included in the income of the recipient pursuant to paragraph 56(1)(u) of the Act. ...

Therefore, when applying the Guidelines, employment duties performed on this land will not be considered to be performed on a reserve. ...

Employment income is generally considered sourced (“arisen”) in the country where the cross-border employee performs the duties of employment giving rise to such income. ...

With respect to pensions received by the Taxpayers from NATO, some of the pensions may be considered to arise in Belgium, where the headquarters of NATO is located. ...

Consequently, the allowance constitutes compensation and is considered remuneration. ...

17 December 2018 Internal T.I. 2016-0659031I7 F- Attendance of board of directors meeting by phone Unedited CRA Tags 2(3), (6)(1)(c), 115(1)(a); 248(1) “office”; 153(1)(a), ITR 10 Principal Issues: Is a non-resident director who, while physically outside of Canada, participates, by phone, in a board meeting held in Canada, considered to be performing duties of offices and employments in Canada? ...

Consequently, the amount of Part XIII tax paid by Canco on behalf of Sisterco would not be included in computing the income of Sisterco under subsections 15(1) or (2) because, respectively, on the one hand, Sisterco is not a shareholder of Canco and, on the other hand, Sisterco would not be considered to a have received a loan from or become indebted to Canco. ...

Considering that the testing period of three months is not required to be consecutive, the term “three months” should be considered to refer to the aggregate time measured by the number of months. ...

However, a person who sojourns for that period of time in XXXXXXXXXX may be considered a deemed resident of XXXXXXXXXX. ...