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Training costs will be considered to be capital in nature where the training results in an enduring or long-term benefit to the participant, for example where a new skill or qualification is acquired. Where, however, the training is taken merely to maintain, upgrade or update an existing skill or qualification, the related training expenses will not be considered to be on capital account. ... In the event that a new skill or qualification is acquired such that the training costs are considered to be on capital account, such costs will not be deductible but should qualify as an eligible capital expenditure. ...

6 October 2004 External T.I. 2004-0093211E5- Lifelong Learning Plan- Full-time student Unedited CRA Tags 146.02(1) Principal Issues: Is a student enrolled in an education program at an educational institution that requires the student to spend 16 hours per week on the program, considered to be a full-time student for purposes of participating in the lifelong learning plan (LLP) Position: Question of fact. ... It is our position that it is the responsibility of the educational institution to determine whether or not the designated person is considered to be a full-time student. It should be noted that even if the student is enrolled in a program that requires spending 10 hours or more per week on courses or work in the program, it would not be eligible for the LLP if the institution considered the student to be part-time. ...

As discussed in paragraph 9 of Interpretation Bulletin IT-357R2- Expenses of Training, a convention is considered a formal meeting of members for professional or business purposes unlike a training course that generally has a classroom format for teaching a subject in accordance with a formal course of study. ... Where a taxpayer is carrying on a business or practising a profession and incurs training costs, these costs may be considered personal expenses, current expenses, or capital expenditures. ... Training costs that result in a lasting benefit to the taxpayer are considered capital in nature. ...

Further, you state that the individuals are authorized to perform spiritual duties that the regular pastor performs and are considered full-time ministers by the church. ... Further, an income tax ruling can only be considered where the transactions are submitted in the manner set out in Information Circular 70-6R5. However, we have considered your enquiry and provide the following comments, which are of a general nature only. ...

It is our understanding from speaking with valuators within the Canada Revenue Agency, that in assessing the reasonability of fair market valuations used by taxpayers, it is the quality of the appraisal(s) relied upon by the taxpayer that is considered. Where a taxpayer obtains three appraisals it should not be assumed that adopting the middle value would be considered proof of the reasonability of the fair market value of the donated property. For further guidance on what factors may be considered relevant to the Canada Revenue Agency in assessing the reasonableness of a fair market value appraisal to be relied upon by a taxpayer, you may wish to submit, in writing, the particular details of your factual situation and your valuation concerns to: Mr. ...

8 December 2004 External T.I. 2004-0091401E5- Medical Expense- Shiatsu Unedited CRA Tags 118.2 118.4(2) Principal Issues: Is a Shiatsu Therapist considered a medical practitioner for purposes of the Medical Expense Tax Credit? ... The reference in paragraph 3 of IT-519R2 (Consolidated) to a therapeutist, or therapist, is a general reference to a number of different health professionals, to whom payments may be considered to be amounts paid to a medical practitioner for medical services. ... Therefore, a fee paid to a Shiatsu Therapist in Ontario for shiatsu therapy is not considered to be an expenditure which qualifies as a medical expense for purposes of the medical expense tax credit. ...

On the basis that the policy you described is considered a group sickness or accident insurance plan under the pertinent legislation, it is our view that payment of the premiums by the employer (Division 1) would not constitute a taxable benefit for employees by virtue of subparagraph 6(1)(a)(i) of the Act. ... However, we agree with your view that should the plan not be considered sickness insurance under the laws of British Columbia the payment of the premiums by the employer will likely result in a taxable benefit for employees. We have contacted the Insurance Department of the British Columbia Financial Institutions Commission and were informed that they have not previously considered whether sickness insurance includes critical illness insurance benefits paid without the occurrence of a loss. ...

Interpretation Bulletin IT-337R4, Retiring Allowances ("IT-337R4") discusses what is meant by a retiring allowance and discusses the taxation of amounts that are considered to be a retiring allowance. ... Where such an amount is more appropriately described in paragraph 11 of IT-337R4, such an amount would be considered to be a retiring allowance. ... Otherwise, such compensation would be considered a retiring allowance, within paragraph (b) of the definition thereof in subsection 248(1) of the Act. ...

the partnership earns income from a property that was owned by it throughout that period, unless, in that period there was a substantial contribution of capital or a substantial increase in the indebtedness of the partnership. 1) In our view, the intent of subsection 40(3.15) is that the two conditions of that subsection should be considered mutually exclusive. Since, in your situation, the partnership did not "actively carry on a business that was carried on by it throughout the period beginning February 22, 1994" nor did the partnership "earn income from a property that was owned by it throughout that period" the partnership interest will not qualify as an excluded interest. 2) Paragraph 40(3.16)(d) of the Act provides, for the purposes of subsection 40(3.15), that an amount will be considered not to be substantial where the amount is used for an activity that was carried on by the partnership on February 22, 1994 but not for a significant expansion of the activity nor for the acquisition or production of a film production. In your situation, if the refinancing is not for expansion purposes or for the acquisition or production of a film production and is for the purpose of carrying on an activity that was carried on by the partnership on February 22, 1994, the increase in the indebtedness of the partnership would not be considered substantial. ...

9 March 2005 External T.I. 2005-0113051E5- Debt Parking and Shareholder loans Unedited CRA Tags 80.01(7)(b) 39(1)(c) 50(1) 80.01(8) Principal Issues: Is a shareholder loan debt of a CCPC written off by the creditor-shareholder under subsection 50(1) considered a "parked debt" Position: Yes Reasons: Wording of 80.01(6)(b) and 80.01(7)(b) and 80.01(8) XXXXXXXXXX 2005-011305 C. ... You specifically ask whether a shareholder loan, which represents a debt of a CCPC that has been written off by the creditor-shareholder as a business investment loss under paragraph 39(1)(c) of the Act pursuant to the bad debt recognition provided by subsection 50(1) of the Act is considered a "parked debt" under the debt forgiveness rules of section 80 of the Act. ... For purposes of the "debt parking" rules an obligation is considered to be a specified obligation pursuant to subsection 80.01(6) of the Act after the obligation is deemed to have been reacquired pursuant to subsection 50(1) of the Act. ...