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10 July 2013 Internal T.I. 2013-0478851I7- Earned income for RRSP purposes CRA Tags 6(1)(f) 146(1) 6(1)(f.1) Principal Issues: Whether Earnings Loss Benefit Payments and XXXXXXXXXX received by a taxpayer are considered earned income for RRSP purposes. ... You are concerned that ELB payments and XXXXXXXXXX payments may not be considered earned income for RRSP purposes primarily because recipients may not be current employees of the XXXXXXXXXX. ... Accordingly, where the ELB and XXXXXXXXXX payments provided to Individuals are included as income from an office or employment under paragraphs 6(1)(f.1) and 6(1)(f) of the Act, respectively, these amounts would be considered "earned income" for RRSP purposes. ...

Whether or not a subscription receipt is considered to be a qualified investment would be a question of fact. ... In your letter to us, you have asked us whether or not subscription receipts that provide the holder with the right to receive a cash settlement in lieu of the underlying property, would be considered a qualified investment. Generally, money and deposits of money will be considered to be a qualified investment provided the money is legal tender in Canada. ...

Position: The payment will be considered an employment benefit and taxable to the employee under paragraph 6(1)(a) of the Act. However, the payment will not be considered the payment of a premium to the RRSP, nor a gift to an RRSP for purposes of Part X.1 of the Act. ... However, the payment will not be considered the payment of a premium to the RRSP, nor a gift to an RRSP for purposes of Part X.1 of the Act. ...

Reasons: Two years is considered to be a reasonable guideline for employment that purports to be a temporary assignment. ... The two years is considered to be a reasonable guideline for employment that purports to be a temporary assignment. ... Accordingly, we have not considered your request further. We trust that these comments will be of assistance. ...

If a contract constitutes a sale of chattels, proceeds from the sale is generally considered to be on account of income. By analogy to the case of Orlando, 62 DTC 1064 (SCC), selling timber may be considered as a scheme of profit making or an adventure in nature of a trade for the purpose of section 9 of the Act. ... If a contract constitutes a grant of an interest in land or a licence analogous to a profit à prendre, proceeds from the grant or the licence may be considered as on account of capital. ...

Antle (613) 957-2102 September 10, 2002 Dear XXXXXXXXXX: Re: Reimbursement of Child Care Expenses This is further to your letter of August 19, 2002, concerning whether the reimbursement of child care expenses by an employer would be considered a taxable employment benefit. ... Where additional child care expenses are incurred because an employee is required by the employer to travel out of town on employment-related business, then the reimbursement of these additional child care costs will not be considered a taxable employment benefit. ... In any other case, the reimbursement of the child care costs would be considered a taxable employment benefit to the employees. ...

For the purposes of the IRC, NRco is considered to be organized under the laws of Delaware by virtue of having been continued in that state, although it has not been considered to have been incorporated in Delaware. As a result, NRco is considered to be a domestic corporation for the purposes of the IRC and is, thus, liable to pay tax in the U.S. on its worldwide income. ... It is our opinion that under the fact scenario described above, NRco is considered to be a resident of the U.S. for the purposes of the Convention. ...

Position: In the circumstances described, it is our view that the right to the additional amount would be considered a separate property having an adjusted cost base of zero. ... You describe the following situation: A taxpayer sold farm property (the " farm property") in 1990, and claimed the capital gains exemption, since the property was considered qualified farm property. ... In the circumstances described, it is our view that the right to the additional amount would be considered a separate property having an adjusted cost base of zero. ...

The fact that the liquidation is required to fund the annuitant's participation in the LLP would not result in the commissions being considered costs incurred by the annuitant. Consequently, these costs would not be considered in determining the amount received by an individual under the LLP as they are expenses of the RRSP. ... In this situation, the annuitant would be considered to have received $10,000 and not $10,526. ...