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We have responded to you directly, rather than the client, as the waiver of interest and penalties, as discussed below, must be considered. ...

The issue as to when the certificate required under paragraph 118.2(2)(e) of the Act must be issued was considered in Kushnir et al. v. ...

More recently, the CCRA has taken the position that Indian bands that do not meet either of these requirements can be considered on a case-by-case basis to determine whether the band performs a function of government such as negotiating and implementing Treaty Land Entitlements. ...

Furthermore, the indirect compensation for these expenses, by the spectators, through the charge for tickets at a sporting venue, would not be considered compensation for food in the ordinary course of the business carried on by the sports team. ...

You have also requested our comments with respect to the determination of the appropriate date that the pay equity payments are considered to have become payable to the Recipients. ...

As such, an accrual note held by an individual may be considered a prescribed debt obligation pursuant to paragraph 7000(1)(d) of the Regulations such that an amount of interest as calculated pursuant to paragraph 7000(2)(d) of the Regulations is deemed to accrue to the taxpayer for the purpose of subsection 12(9) of the Act. ...

However, as noted in paragraph 9 of Interpretation Bulletin IT-337R3 Retiring Allowances, where the portion of the award or settlement amount that is in respect of damages can be shown to be related to a violation of the prevailing human rights legislation, then that portion will not be considered a retiring allowance, and will not be included in the employee's income. ...

The enforcement of a pre-existing entitlement under an existing agreement in respect of a division or settlement of property would be considered to be separate and distinct from the original division or settlement of property arising out of the marriage breakdown. ...

The paragraphs apply to payments made after 1996, where a written agreement or order of a competent tribunal made at any time in a taxation year provides that an amount paid and received before that time and in the year or the preceding taxation year is to be considered to have been paid and received thereunder (the "retroactive provision"). ...

You are asking whether the pay equity interest portion would be considered a tax exempt windfall since the payments are being made as a result of a court decision involuntarily imposed on the federal government. ...