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The premium is considered a personal expense of the individual. 2.Does a company have to be incorporated to set up a plan for other employees? ... Amounts are considered reasonable if they do not exceed amounts that are actuarially determined as being in respect of the coverage provided by the plan for the group of employees being covered. ... Where the upper management group is comprised of shareholders, the remarks under question 5 below should be considered. 5.Can a Private Health Plan be set up for a shareholder of a company? ...

In determining where a particular type of business is carried on, the Department usually relies on the following guidelines: (a)     Development and sale of real property- the place where the property is situated; (b)     Merchandise trading- the place where the sales are habitually completed, but other factors such as the location of the stock, the place of payment or manufacture may be considered relevant in particular situations; (c)     Trading in intangible property (e.g., stocks and bonds)- the place where the purchase or sale decisions are normally made; (d)     Money lending- the place where the loan arrangement is in substance completed; (e)     Personal property rentals- the place where the property available for rental is normally located; (f)     Real property rentals-the place where the property is situated; (g)     Service- the place where the services are performed."-     Paragraph 27 of Interpretation Bulletin IT-270R2 states that: "In the case of a single business comprising more than one of the above mentioned activities, each segment is considered separately in determining in which country or countries the business is carried on. ... If the XXXXXXXXXX is considered to be carrying on business in Canada, the next step would be to determine whether the XXXXXXXXXX has a permanent establishment in Canada pursuant to Article V of the Canada-Belgium Income Tax Convention (the "Convention"). ...

However, as the February 10, 1984 Head Office Appeals memorandum suggests, where it can be demonstrated that the cash and short-term investments were not held for the purpose of use in the business, but for some other purpose, such as (a)     the making of an investment that is not incidental to and does not pertain to the active business of the taxpayer; or (b)     the payment of dividends to shareholders, then the cash and short-term investments so used should be considered to have been in excess of business requirements and should be included in the taxpayer's investment base until such time as they were so used. ... If it does, then it is a question of fact whether the shareholder loans pertain to that business and whether such business qualifies as a "specified investment business" within the meaning of paragraph 125(7)(e)). 24(1) Issue 5: 24(1)  24(1)  based on the following comments from paragraph 3 of Interpretation Bulletin IT-73R4:      "Where the original gain on the sale of real property was categorized in a previous year as income from an active business, amounts included in income in subsequent years in respect of the realization of the mortgage reserve pursuant to subparagraph 12(1)(e)(ii) are considered to be income from an active business.  ... Short-term investments are thus ordinarily considered not to be in excess of a taxpayer's requirement for funds for use in its active business and are thus ordinarily excluded from the investment base of the taxpayer.  ...

If penalties and interest on B.C. logging taxes were considered as "logging taxes" for the purposes of the B.C. ... There is an argument that the expression "logging taxes paid" used in paragraph 127(1)(a) of the Act could be considered to include all taxes and all penalties and interest that are or may be added to taxes under the B.C. ... In rebuttal of the argument in 7 above, we note that the definition of "taxes" uses the word "includes" instead of "means", which indicates that a reference to "taxes" is not always considered as a reference to all taxes and all penalties and interest. ...

Regardless of whether the renting of a property results in business income or property income, a taxpayer will be considered to have a "leasing property" and be restricted to the amount of CCA that may be claimed on that property, unless one of the exceptions noted below are met. ... Therefore, revenue derived from the chartering of a houseboat without a crew would normally be considered as rental or leasing revenue regardless of the other ancillary services provided as part of the charter arrangement or small fees collected therefrom.      However, revenue received from providing ancillary services will not be treated as rental income for the purposes of the 50% test above if the entity renting the houseboat provides sufficient services such that it is considered to be carrying on a business add it also meets one of the requirements outlined below: a)     an individual operates a sole proprietorship and be is personally active on a continuous basis in the day to day operation of the business throughout the portion of the year during which the business is ordinarily carried on; b)     the business is carried on by individuals in a partnership and the partners who are personally active in the business on a continuous basis are entitled to share in at least two-thirds of the income or loss of the partnership; or c)     the business is carried on by a corporation. ...

Also, unrelated persons should ensure a mortgage has market terms, otherwise, they could be considered by paragraph 251(1)(b) not to be dealing at arm's length. for DirectorFinancial Industries DivisionRulings Directorate ...

As a result of this election the NPO for purposes of computing the GST "Input Tax Credits" would be considered to be carrying on commercial activities.  ...

From a review of the Constitution and By-laws, it would appear that the  24(1) is exempt from Part 1 Tax under paragraph 149(1)(e) of the Act, that an agricultural organization is an entity organized and operated for one or more of the following purposes: the advancement or furtherance of agricultural; the betterment of the conditions of those engaged in such pursuits; the improvement of the grade or quality of their pursuits or the development of a higher degree of efficiency in their respective occupations. 24(1)  would, in our view, be considered to be an agricultural organization.  ...

Background In 1984 the Review Committee considered the above issue (D.S. 5021-5) and adopted the position that a deceased person and his estate are not non-arm's length for purpose of section 84.1. ...

Furthermore, in order for a particular entity to be considered such an Agent of the Crown, the law creating the entity must expressly make it an Agent of the Crown or it must be an Agent of the Crown at common law. ...