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Reasons: To be considered ongoing, the Regulations specify a minimum duration of five or more consecutive days. ... To be considered ongoing, the Regulations specify that a program must be a minimum duration of five or more consecutive days of which more than 50 percent of the daily activities include a significant amount of physical activity. ...

Comments: While always a question of fact, it appears likely that the co-operative housing corporation would be considered to be a non-profit organization ("NPO") under paragraph 149(1)(l) of the Act. ... Specifically, paragraph 3 of IT-304R2 in discussing condominium corporations that are not NPOs states that, "Any excess of members' condominium fees and contribution over the corporation's expenditures for the year is not considered to be income of the corporation. ...

As you indicated, at the 2005 CALU Conference (2005-0116661C6) and in 2004-007034, we considered situations where a taxpayer used borrowed money to pay interest on an earlier loan. In our view, the situations you describe are not the same as or similar to those considered in those documents. ...

25 February 2008 External T.I. 2007-0237891E5- Uniforms and Clothing Allowances Unedited CRA Tags 6(1)(a) Principal Issues: Whether the provision of a shirt, which bears the company logo and is required to be worn in the course of employment, by an employer to an employee is considered a taxable benefit to the employee? Position: No Reasons: The shirt would generally be considered a distinctive uniform (see IT-470R paragraph 29). 2007-023789 XXXXXXXXXX Shaun Harkin, CMA (613) 957-9229 February 25, 2008 Dear XXXXXXXXXX: Re: Technical Interpretation Request- Uniforms and Clothing Allowances This is in reply to your email of May 28, 2007, regarding uniforms and special clothing. ...

Since the amount of the penalty under subsection 162(1) was nil, the taxpayer should not be considered to have been liable to a penalty under that subsection. ... It is CRA's view that a non-resident corporation would still be considered to be liable to a penalty under subsection 162(1) even though the calculated amount of the penalty under that subsection may be "nil". ...

There are, however, a number of other factors that have to be considered in determining if the exemption would apply to a particular individual. ...

No economic benefit considered received 2006-020438 XXXXXXXXXX Jack Szeszycki (613) 957-8972 March 2, 2007 Re: Taxability of Allowance for Purchase of School Supplies We are responding to your letter of July 27, 2006, in which you requested confirmation of your understanding of the proper tax treatment for a one-time, negotiated payment to teachers in respect of past purchases of school supplies. ... It is the Agency's general view that where an amount is paid to an employee on a one-time basis as a reimbursement in respect of expenditures made by the employee that would normally be the responsibility of the employer, the amount received by the employee would not be considered a taxable benefit and therefore would not be required to be included on the individual's T4 information slip. ...

A reduced interest or an interest-free loan exchanged for reduced club dues is considered to be a barter transaction. ... In our view, the club dues reduction falls into the meaning of the words in paragraph 2 of Interpretation Bulletin IT-396R, entitled Interest Income which states in (b) that a taxpayer is considered to receive a payment when there is an offset against an amount owing by the taxpayer. ...

From the limited information you have provided, it appears that you are considered a factual resident of Canada for income tax purposes. The term factual resident means that, although you left Canada for a period of time, you are still considered to be a resident of Canada for income tax purposes. ...

It flows through when shares are transferred at ACB on a rollover basis, to the extent it can be considered to contribute to the gain on the shares. ... Where the shares are disposed of as a consequence of the death of the individual at ACB because subsection 70(6) applies, we are of the view that the safe income that can reasonably be considered to contribute to the accrued gain on those shares at that time would flow through to the acquirer of the shares. ...