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Principal Issues: Whether hardship and danger allowances received by employees working for a company in XXXXXXXXXX under a contract with the military would be tax-free Position: Probably not Reasons: Unless the allowance can be considered to be in respect of travel expenses, or for board, lodging or transportation at a special worksite, it would be taxable. ...

The Tax Court of Canada has considered the issue of whether the cost of a hot tub is a qualifying medical expense in a number of cases, with the Court allowing the cost of a hot tub in some instances, and not allowing it in others. ...

In most situations, a corporation is considered to be resident in the country in which its central management and control is exercised. ...

In this regard, XXXXXXXXXX is considered a remote place. With respect to the taxation of the housing loss, where an employee is moved to a remote location and the move was an eligible relocation as defined under subsection 248(1) of the Income Tax Act, the housing loss can qualify for beneficial tax treatment, providing it was understood at the time that the employee would be compensated for a loss suffered on the sale of his or her house when relocated out of the remote place,. ...

Position: Decisions are not precedent setting and therefore not considered binding on the CCRA. ...

An arrangement under which a sole proprietor (who has no employees) pays an administrator a fee to be reimbursed for his or her actual medical expenses as well as those of other household members, is not considered to be a plan of insurance. ...

Any allowances which reimburse an individual for expenses considered to be personal in nature would be required to be included in income. ...

An arrangement under which a sole proprietor (who has no employees) pays an administrator a fee to be reimbursed for his or her actual medical expenses, as well as those of other household members, is not considered to be a plan of insurance. ...

When an employee or officer incurs legal costs as a result of an action performed while carrying out his or her duties, in most cases no real benefit is considered to accrue to the employee or officer. ...

Accordingly, when the benefits under these programs cease or are reduced, this does not constitute an event that falls under the GIS optional income provisions and the assistance must be considered in establishing entitlement to the GIS. ...