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Given the fact that a fishing licence cannot be issued to a corporation and that the terms of the fishing licences do not permit anyone other than the licence-holder to fish under that licence, should the income earned from fishing be considered to be the individual's income rather than the corporation's? ...

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

Any amount paid in 1997 to the spouse of the deceased annuitant as a consequence of the death is considered a "refund of premiums" as defined in subsection 146(1) of the Act except for that portion which is a "tax-paid amount". ...

Shares Held "In Trust" If it is established that the shares of the Corporation are held in trust by the members of the Organization, as agents for the Organization, the Organization would be viewed as the beneficial owner of the shares and any capital gain which would result on the transfer of the shares would be considered to be a capital gain of the Organization. ...

Exclusion under subsection 6(6) Subsection 6(6) of the Act allows certain allowances in respect of personal or living expenses, normally considered a taxable benefit under paragraph 6(1)(b) of the Act, received by individuals employed at special work sites and remote work locations, to be excluded from income. ...

Given the fact that a fishing licence cannot be issued to a corporation and that the terms of the fishing licences do not permit anyone other than the licence-holder to fish under that licence, should the income earned from fishing be considered to be the individual's income rather than the corporation's? ...

To the best of your knowledge and the knowledge of the Employer, none of the issues involved in this ruling request is being considered by a tax services office or taxation centre in connection with an income tax return already filed, and none of the issues is under objection or appeal. ...

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

In our view, at the time of this novation, the Partnership would be considered to have made a payment or credit in kind of the Accrued Interest to the Creditor Affiliate by delivering the Debtor Affiliate’s covenant to make the payments under the Loan agreement to the Creditor Affiliate. ...

However, based on the information provided to us, it seems unlikely that any portion of the $XXXXXXXXXX loan to the XXXXXXXXXX could be considered to be a loan granted by virtue of their employment with the corporation. ...