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You are asking whether the fees paid for the collection of umbilical cord blood (UCB) would be considered to be medical expenses for purposes of the medical expense tax credit ("METC"), when such collection is recommended by a specialist. ... We have also considered the application of paragraph 118.2(2)(o) of the Act which allows amounts paid for laboratory, radiological or other diagnostic procedures or services prescribed for a patient by a medical practitioner or dentist. ...

As also indicated in paragraph 25 of that Interpretation Bulletin, where a person (i.e. the "lessor") leases property that is used by another person in a farming business, such property is generally not considered as farm property to the lessor. This is because such property is considered to generate income from property in the hands of the lessor. ...

Paragraph 6 of Interpretation Bulletin IT-428, Wage loss replacement plans, dated April 30, 1979, states that a WLRP will be considered to exist where payments under the plan are to commence only when sick leave credits are exhausted. ... Therefore, a STD or LTD payment made through the use of sick leave credits would not be considered a payment made under a WLRP, but would be an employment benefit under paragraph 6(1)(a) or deemed remuneration under subsection 6(3) of the Act and should be reported on a T4 slip. ...

Position: Yes Reasons: Economic benefits received by employees in respect of their employment will be considered a taxable benefit even if the benefit is not provided by the employer XXXXXXXXXX 2011- 040972 B. ... Therefore, all employees that purchase the software at the reduced price will be considered to have received a taxable benefit in respect of their employment equal to the difference between the fair market value of the software and the amount paid for the software. ...

An individual's ability to perform a basic activity of daily living is considered to be markedly restricted only if the individual is blind, or is unable to perform a basic activity of daily living, all or substantially all (at least 90%) of the time, even with therapy, the use of appropriate medical devices and medication. ... Generally, disabling ailments and conditions must be considered on a case-by-case basis, since it is the effect of the impairment on the ability to perform the basic activities of daily living that determines whether an individual has a severe and prolonged impairment. ...

There are publications produced by the Canada Revenue Agency ("CRA") that provide guidance on factors that should be considered in establishing whether a particular gain is on account of capital or income. ... However, in making such determinations, the courts have considered different factors such as those explained in IT-218R. ...

It may be considered social assistance under 56(1)(u), with a corresponding deduction under paragraph 110(1)(f), or it may be included in income as business income. ... The payments received may be considered social assistance under the Act. ...

Under the ITA and the CPP, such a person is considered to be the taxpayer's legal representative, while under the EIA and the ETA, that person is referred to as the taxpayer's responsible representative. ... Under the EIA and the ETA, such persons are considered to be the taxpayer's responsible representative. ...

Specifically, you asked for our views on whether a cooperative corporation ("Subco") that is a wholly-owned subsidiary of another cooperative corporation ("Parentco") is considered to have made a "payment" as defined in subsection 135(4) of the Act when Parentco issues shares of Parentco to Subco's members in satisfaction of Subco's patronage allocation. ... Accordingly, it is our view that Subco will not be considered to have made a "payment" as defined in subsection 135(4) of the Act. ...

13 July 2010 External T.I. 2009-0348951E5- Taxation of payments made by union to its members Unedited CRA Tags 56(1)(a)(ii), 248(1) "retiring allowance" Principal Issues: Will certain payments made by a union to its members be considered to be a retiring allowance or a non-taxable payment? ... Only if the answer to the first question is "no" and the answer to the second question is "yes", will the amount received be considered a retiring allowance. ...