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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. ...

Lottery winnings are generally not taxable as they are not considered income from a source, pursuant to 40(2)(f). 2010-036026 XXXXXXXXXX Gillian Godson (613) 957-9229 May 11, 2010 Dear XXXXXXXXXX: Re: Employee Lottery Ticket Winnings This is in response to your email of March 12, 2010, wherein you requested information regarding the tax implications of gifts of provincially-run lottery tickets to employees, in particular if the employee should win a prize as a result of a gift of a lottery ticket from an employer. ... The receipt of a lottery prize is generally not taxable as it is not considered income from a source of employment, business or property, and therefore would not be included in the calculation of taxable income. ...

Reasons: The particular iontophoresis device is considered a qualifying electrotherapy device under paragraph 5700(z.2) of the Regulations. ... Since iontophoresis involves the therapeutic use of electricity and as the iontophoresis device described in your letter has been designed for the treatment of hyperhidrosis, it is our view that such a device would be considered a qualifying electrotherapy device under paragraph 5700(z.2) of the Regulations. ...

You wish to know whether the settlement payment would be considered non-taxable as damages received for personal injury. ... 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. ...

Whether payment of legal costs by trustee would be considered a contribution to trust and invoke attribution rules? ... In addition, you have asked whether the payment of the legal costs by the trustee would be considered a contribution to the trust and cause the application of the attribution rules. ...

If the expenses were paid by someone other than the annuitant of the RRSP or the spouse of the annuitant, the payments would be considered gifts to the RRSP. ... Any amounts not deposited into the RRSP would be considered withdrawals from the RRSP and would be included in the income of the annuitant in the year of the withdrawal. ...

Reasons: The lump-sum settlement is generally considered a retiring allowance and the amount to be withheld can be found in subsection 103(4) of the Regulations. ... A lump-sum amount received in a wrongful dismissal settlement is generally considered a "retiring allowance". ...

23 September 2010 External T.I. 2010-0379201E5- Allowable Business Investment Loss Unedited CRA Tags 38(c); 39(1)(c); 50(1) Principal Issues: Whether losses realized in the fact situation provided would be considered an allowable business investment loss pursuant to paragraph 38(c) of the Income Tax Act. ... We are writing in reply to your correspondence dated August 18, 2010, wherein you requested a ruling in determining whether certain losses realized by your clients would be considered an allowable business investment loss ("ABIL") pursuant to paragraph 38(c) of the Income Tax Act (the "Act"). ...