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This was being considered because, although the capital gains deduction eliminates any income tax with respect to the license buy-back in most cases, it does not reduce the income inclusion's impact on eligibility for the GIS. ... An exception did occur in the late 1970's, when grants received to cancel lobster fishing licenses were considered to have no tax consequences. ...

Health care premiums that are paid by an individual and that are reimbursed by an employer, former employer or superannuation find are taxable in the hands of the individual, because these payments are considered to be a reimbursement of personal expenditures of the individual. As with other expenditures that are the personal liability of an individual, when an employer pays these premiums or reimburses an employee for such payments, the employee is considered to have received a taxable employment benefit according to existing income tax legislation. ...

You enclosed a copy of a booklet describing the 24(1)  Our response is based on the following assumptions concerning the employee share purchase plan: 24(1) 24(1) We would first like to point out that share purchase arrangements for employees are generally subject to the provisions of section 7 of the Act to the extent that the shares are issued by or acquired from the employer corporation or a corporation with whom the employer does not deal at arm's length and that any benefit calculated thereunder is considered to be remuneration from employment. 24(1) With respect to the third criteria, it is our view that the time at which the agreement is made is the effective date at which the corporation is committed to issuing the shares specified in the agreement.  ... We caution that the foregoing represents our considered opinion only and is not binding on the Department. ...

Humenuk   (613) 957-2135 July 25, 1989 Dear Sirs: Re:  Attribution Rules We are responding to your letter dated May 19, 1989, in which you ask whether the repayment of a loan in kind is considered a transfer within the meaning of subsection 74.1(1) of the Income Tax Act (the Act). ... X is not considered a transfer it is our view that subsection 73(1) of the Act does not apply to Mrs. ...

., the processing of farm products), it is a question of fact dependent upon the circumstances of the case as to whether or not the farming operation can be considered a separate business for which the farmer can elect to report the income using the "cash" method.  Normally, z taxpayer will be considered to operate two separate business if the businesses are not so interlaced, interdependent and interconnected that it is virtually impossible to separate one operation form the other.  ...

This will confirm that for the purposes of the Convention and other treaties comparable thereto we have adopted the position that an organization that is resident in a Contracting State will generally be considered to be a "resident of" that State notwithstanding that it is granted exemption from tax in such State by the tax laws thereof. ... While the foregoing is generally our position, so far as we can determine this issue has not been previously considered in respect of a trust (other than a trust that was exempt under Article XXI). ...

The amount of the income or profits tax that would be considered to have been paid by the taxpayer to the government of Germany in respect of the grossed-up dividend for the purposes of the Canadian Income Tax Act (the "Act") would be equal to the portion of the aggregate German income tax paid by the taxpayer for the year that can be reasonably be considered to have been paid on the amount of the grossed-up dividend. ...

Payments to employees to cover personal expenses are normally considered taxable benefits to employees under paragraph 6(1)(a) of the Income Tax Act. ... Further, paragraph 18(1)(a) of the Act does not permit the employer to make a deduction when calculating its general business income since the payments will not be considered outlays or expenses made or incurred for the purpose of gaining or producing income from the business. ...

Although getting to work is a personal responsibility and employer-provided assistance to do so would generally give rise to a taxable benefit, when an employee travels from home to a work-related point of call other than his or her regular place of employment, such travel is not considered personal and would not give rise to a taxable benefit. ... However, if the employer pays a school bus driver instead of a third party to clear the snow, the amount is considered a taxable benefit. ...

Position: Not considered to be "supplies consumed directly in the performance of the duties of employment". ... The fixed expenses incurred for a telephone line and monthly Internet access fees are not deductible under subparagraph 8(1)(i)(iii) because they are not considered to be supplies that were consumed directly in the performance of the duties of employment. ...