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When the employee does not admit liability in the agreement for the repayment of amounts to the employer, are the amounts repaid considered a repayment of amounts previously included in income? ...

As to the rolling back issue this was considered in a similar fact situation (i.e., income had been deferred and a roll-back would have created a permanent revenue loss) in Casey Realty Limited and Chignecto Holdings Limited v. ...

Principal Issues: Does a contribution to a French pension plan have to be made in the year the services are rendered in order to be considered as a contribution to a Canadian pension plan, as suggested by the English version of the Canada-France tax treaty? ...

If the Roth IRA is not considered a pension plan, the decision in Abrahamson (91 DTC 213) would likely have application to most payments received from a Roth IRA (i.e. the Roth IRA is a non-resident inter-vivos trust- amounts withdrawn from the trust are capital, except for earnings in the year). ...

Paragraph 5 of IT-433R states that: “The value of a cheque that is received by a taxpayer who uses the cash method to compute income is considered to be income at the time the cheque is received from a person who was indebted to the taxpayer provided the following conditions are applicable: (a) the debt is payable at the time the taxpayer receives the cheque,... ...

In our view, the training assistance received by the individuals described above, under Part II of the EI Act or under the EFP or Apprenticeship Branch 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. ...

As her remuneration was considered exempt under the Indian Act, it was excluded from the computation of income under paragraph 81(1)(a) of the Income Tax Act (the "Act"). ...

-What factors must be considered to determine whether an amount qualifies as a scholarship to the recipient? ...

A series of periodic payments is considered to be a series of at least three equal (or similar) amounts paid at certain specified intervals. ...

We also considered the situation where 118(5) does not preclude the t/p from claiming a personal tax credit: in such a situation the facts may show that the taxpayer is otherwise not entitled to a credit for the child. ...