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In relation to this comment, where an obligation to make a payment is settled by a transfer of property, the payment is generally considered to have been made at the time of the transfer. ...

In general, where a business is operated entirely on a reserve and the clients of the business are Indians living on reserve, the business income would be considered to be connected to a reserve and thus exempt from tax in the hands of the Indian proprietor. ...

En réponse à cette question, l'ADRC a indiqué la position suivante: It is true that remuneration from a corporation to its principal shareholder-manager and to employee other than the spouse and immediate family of the principal shareholder-manager will not generally be considered excessive where it is the practice to distribute corporate profits to shareholder-employees or employees or where corporate policy is to recompense the shareholder-manager(s) for corporate profits that are attributable to his special contribution. ...

As indicated in your memorandum, unless XXXXXXXXXX can be considered a CFA of the Canadian-resident corporations which form part of the remaining partners of XXXXXXXXXX, these partners will be subject to the provisions of subsection 17(1) of the Act. ...

Rather, the relevant facts and information in relation to the requirements in the Act must be considered in determining the tax treatment of the payments made in XXXXXXXXXX which total $XXXXXXXXXX. ...

When training benefits are received by status Indians, paragraph 81(1)(a) of the Act and section 87 of the Indian Act may provide a tax exemption if the income is considered an Indian's personal property situated on a reserve. ...

The corporation would be considered to be carrying on the business if the activities of the corporation, and its relationship to its employees and clients, are similar to those ordinarily associated with a corporation carrying on a business. ...

The Department accepts that a student is under instruction and direct supervision while flying solo; consequently, the cost of dual and solo flying hours required to obtain the following licences or ratings, to the minimum flight training requirements of the Department of Transport, is considered to be part of the student's tuition: (a) Private Pilot Licence- aeroplane; (b) Private Pilot Licence- helicopter; (c) Commercial Pilot Licence- aeroplane; (d) Commercial Pilot Licence- helicopter; (e) Instrument Rating; (f) Flight Instructor Rating; (g) Night Rating; or (h) Alternate Landplane or Seaplane Rating. ...

Under paragraph 7(10)(c) of the Act, the specified value cannot exceed the amount by which $100,000 exceeds amounts previously claimed under subsection 7(8) of the Act in respect of security options that vested in the same year as the particular security options that were exercised and are being considered for the current deduction under subsection 7(8) of the Act. ...

Applicants must be supervised, and applications are considered the joint effort of the applicant and the supervisor with whom he or she intends to study.? ...