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The question of whether one of the main reasons for the existence or issuance of shares can reasonably be considered to be the reduction or postponement of the amount of taxes that would otherwise be payable, for the purposes of paragraph 95(6)(b) of the Act however, is one of fact that can only be determined with full knowledge of all the particulars of a situation. ...

Where a bank account is considered to be situated at a location on reserve, this is one factor to weigh in determining whether interest earned on deposits in that account is exempt from taxation. ... Her Majesty the Queen (94-1971(IT)G), the Tax Court of Canada considered the taxability of income earned by an Indian living on reserve, from investments purchased from an on reserve branch of a bank. ...

Since this amount was not taxed, however, subparagraph 56(1)(a)(i) of the Act may be applied to tax the amount on its receipt out of the plan since the amount would be considered as a superannuation or pension benefit. b.         ... In accordance with subsection 56(10) of the Act, amounts paid out of the plan will generally be considered to come first our of the RCA segment.  ...

Even if the fees were of the nature that could be considered to be a management fee (this involves a question of fact), they would not be subject to the provisions of 212(1)(a) because of our position outlined in paragraph 2 of IT468R For treaties that do not contain a specific article on management or administration fees (such as the XXXXXXXXXX Convention), 212(1)(a) will not apply to such fees and those fees will be considered to be covered by the treaty article dealing with business profits. ... To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling (i) is in an earlier return of the taxpayers or a related person, (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person, (iii) is under objection by the taxpayers or a related person, (iv) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired, (v) is the subject of a ruling previously issued by the Directorate. ...

If an employee is required to submit receipts or otherwise show the employer how the amount was spent, the amount is considered to be a reimbursement even if the employer calls it an allowance. ...

If the course material is related to your employment, you will not be considered to be enrolled in a qualifying educational program. ...

Levies made during a year on some or all members of a trade union to provide funds for the prosecution of a legal strike of the union are considered to be annual dues provided that such levies are capable of recurring and have not been designated by the union as special assessments. ...

Since tax policy issues and amendments to the Act are the responsibility of the Department of Finance, any changes to the rules regarding the eligibility of travel costs as medical expenses would have to be considered by that department. ...

Considering that a trustee currently has less time to file the trust's income tax return (three months) than corporations (six months) and individuals (four months), changing the T3 filing requirements to further reduce the filing deadline was not considered appropriate at this time. ...

In addition, the Guidelines are not intended to apply when it can reasonably be considered that one of the main purposes for the existence of an employment relationship is to establish a connecting factor between the income in question and a reserve. ...