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Ministerial Correspondence
23 August 2005 Ministerial Correspondence 2005-0140431M4 - Status Indian post secondary education assistance
There are two ways in which income can be situated on a reserve: (i) by a connecting factors analysis under which the amount is determined to be so connected to a reserve that it should be considered to be situated there, or (ii) if the amount has been paid pursuant to a treaty with Her Majesty, section 90 of the Indian Act will deem it to be situated on a reserve for purposes of the section 87 tax exemption. ...
Ministerial Correspondence
23 July 2003 Ministerial Correspondence 2003-0030624 F - Investment Income-Status Indian
However, the investment income generated by such contributions is generally considered to be earned off reserve and, as such, is taxable to a status Indian upon receipt. ...
Ministerial Correspondence
30 April 2004 Ministerial Correspondence 2004-0069871M4 - Definition of person,resident,Canada & individual
An exception from the general rule for trusts is made in subsection 104(1) for certain trusts that can reasonably be considered to act as agent for all the beneficiaries of the trust with respect to the trust property. ...
Ministerial Correspondence
19 September 2001 Ministerial Correspondence 2001-0091864 - INSURANCE POLICYHOLDER TAXATION
The entitlement to a policy dividend is considered to be a partial disposition of an interest in the policy for tax purposes. ...
Ministerial Correspondence
11 January 2002 Ministerial Correspondence 2001-0110644 - 90-DAY SEPARATION PERIOD
Therefore, if the individual is living separate and apart from his or her spouse on December 31, 1999, and so lives for any period of at least 90 consecutive days that includes December 31, 1999, they would not be considered cohabiting spouses at the end of 1999. ...
Ministerial Correspondence
25 April 2000 Ministerial Correspondence 2000-0015044 - TAXATION OF INDIAN FISHING INCOME
You are concerned that the Canada Customs and Revenue Agency (CCRA) has not considered the amount of time an inland fishery spends engaged in fishing activities on land as a factor connecting the fishing income to a reserve. ...
Ministerial Correspondence
19 January 2001 Ministerial Correspondence 2000-0061574 - LEGAL FEES-SUPPORT ORDERS
Accordingly, we decided to accept that legal costs incurred in respect of a child support order issued under the Divorce Act would generally be considered deductible, in keeping with our longstanding position (in paragraph 18 of IT-99R5) that legal costs incurred to enforce pre-existing rights to support amounts are deductible. ...
Ministerial Correspondence
29 July 2020 Ministerial Correspondence 2019-0828011M4 - Medical expenses – IVF and surrogacy
Therefore, the court in Zanatta v The Queen also considered whether paragraph 118.2(2)(a) of the Act infringes on section 15 of the Canadian Charter of Rights and Freedoms. ...
Ministerial Correspondence
25 January 1991 Ministerial Correspondence 903484 F - Overlapping of Tax Instalment Requirements and Withholding Requirements in Respect of Non-Resident Corporations
Based on the scenario described above, you have asked the following questions: a) In the first year of operation in Canada of the joint venture, would the non-resident corporate member of the joint venture (hereinafter referred to as "non-resident") be considered to be a new corporation and therefore instalments would not be required in that year? ...
Ministerial Correspondence
16 January 1990 Ministerial Correspondence HAA4093N14 F - Canada-Netherlands Income Tax Convention - Pension of Public Employees
Generally, benefits received under the General Pensions Act for Public Employees (ABP) are not considered social security benefits. ...