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An amount is generally considered to be received in a person's capacity as an individual, as opposed to his or her capacity as an employee, where the amount is: philanthropic; voluntary; not based on employment factors such as performance, position, or years of service; and not made in exchange for employment services. An amount received by an individual may also be considered a windfall and not taxable. ...

" Based on the foregoing, since a transport truck would be considered exempt property, a lessee and a lessor would not be entitled to elect under section 16.1 of the Act in respect of such a vehicle. ... However, pursuant to paragraph 18(9)(b) of the Act, any rent payments that are denied under paragraph 18(9)(a) may be deducted in calculating a taxpayer's income for the subsequent year to which the outlay or deduction can reasonably be considered to relate. ...

Therefore, Employer A and Employer B would be considered related for the purpose of the calculation in part a) above. ... In our view, the employer contributions would be considered to have vested in the employee. ...

Notwithstanding the above, as indicated in paragraph 4 of Interpretation Bulletin IT-334R2, "Miscellaneous Receipts", voluntary payments (or other transfers of benefits) received by virtue of a profession or by virtue of carrying on a business are considered to be taxable receipts. ... In order for a transfer to be considered as voluntary there must be no obligation to make such a transfer. ...

We can confirm that XXXXXXXXXX is considered to be a prescribed international organization. ... As a result, the income earned in the period would be considered income from a business. ...

You have asked if the sale would be considered as a sale of eligible capital property which would result in a capital gain and how the adjusted cost base for this property could be determined. ... For instance, in the case where the transferor can be considered to be in the business of developing game software, any payments received would be included in business income as a trading receipt. ...

Interpretation Bulletin IT-339R2, Meaning of Private Health Services Plan, sets out the requirements that must be met in order for a plan to be considered a private health services plan (PHSP). ... Pursuant to paragraph 118.2(2)(a) of Act, an amount paid to a medical practitioner, dentist or nurse, or a public or licensed private hospital is considered to qualify as a medical expense of an individual only if it is paid in respect of a medical or dental service. ...

Under paragraph 118.2(2)(q) of the Act, an amount paid as a premium, contribution or other consideration under a private health services plan ("PHSP") is considered to be a medical expense for purposes of the Medical Expense Tax Credit ("METC"). ... In the event such payments are deducted by the individual under subsection 20.01(1) of the Act, they are no longer considered a medical expense for purposes of the METC. ...

The term "long service" is usually considered to have reference to the total number of years in an employee's career with a particular employer or with affiliated employers. ... As such, the LPLP would be considered a retiring allowance and subject to income tax withholding. ...

Under the current wording of the "TCP" definition, an amount equal to that same proportion of the FMV of the shares of the Subsidiary will be considered real or immovable property situated in Canada of the Parent in the determination of whether the shares of the Parent derive their value principally from real or immovable property situated in Canada. ... If the shares of the Parent would be TCP had the Parent capitalized its wholly-owned Subsidiary with only equity, then such shares will be considered TCP if the Parent capitalizes the Subsidiary in part with equity and in part with debt. 3. ...