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23 April 2012 External T.I. 2012-0444341E5- medical expenses- residential treatment center Unedited CRA Tags 118.2(2)(e), 118.2(2)(g), 118.2(2)(h) Principal Issues: Whether amounts paid to a residential treatment center would be considered to be a medical expense? ... A patient suffering from a behavioral problem arising out of a mental or physical handicap who attends a school, institution or other place that specializes in the care and training of persons who have the same type of handicap is considered to qualify under paragraph 118.2(2)(e), and the expenses paid for the patient are qualifying medical expenses. ...

Position: No, unless they are considered as child care expenses under section 63 that are incurred for the purpose of allowing the taxpayer to work, carry on a business or undertake certain certain educational/research activities. ... However, if the payment is for a child under the compulsory school age, the services being provided are generally considered to be for child care rather than education, unless the facts indicate otherwise. ...

It is our view that such partitions could be considered as office furniture or equipment and included in Class 8 for CCA purposes. ... In our view, such a demountable partition system, which appears to be similar to your company’s system, should be considered as an integral part of the building contributing to its effective functioning and, as such, would be included in either Class 3 or 6 of Schedule II, as the case may be, for CCA purposes. ...

Are these non-resident individuals considered employees or independent contractors? ... Specifically you have asked the following questions regarding a XXXXXXXXXX university’s (“University”) proposal to recruit non-resident individuals to teach online courses outside of Canada: Are these non-resident individuals considered employees or independent contractors? ...

Your final question is whether the payment of the life insurance policy premiums by Opco will be considered to be the conferring of a shareholder benefit under subsection 15(1) of the Act if Opco does not deduct the premiums for tax purposes. Generally, premiums paid under a life insurance policy are considered to be on account of capital and therefore are not deductible in computing income pursuant to paragraph 18(1)(b) of the Act. ...

24 June 2016 External T.I. 2016-0632181E5- Form T2201- meaning of medical doctor Unedited CRA Tags 118.3(1)(a.2); 118.4(2) Principal Issues: 1) Is a registered oral surgeon, prosthodontist or other oral specialist considered to be a medical doctor in the Province of Alberta for the purpose of certifying on Form T2201 that an individual has an impairment in speaking and feeding? ... More specifically, you ask whether a registered oral surgeon, prosthodontist or other oral specialist is considered to be a medical doctor in the province of Alberta for the purpose of certifying on Form T2201 that an individual has an impairment in speaking and feeding. ...

Both types are considered corporations for purposes of the Act. Such corporations are subject to a withholding tax of 23% under Part XIII, subsection 212(5.1), on the amounts paid or credited, or provided as a benefit, to or on behalf of the actor for the provision in Canada of the acting services of the actor in a film or video production (“acting services”), unless the corporation elects to file an income tax return and pay tax under Part I pursuant to subsection 216.1(1). ... If the elective return is filed late, the election will be considered invalid. ...

We have carefully considered the points raised. As noted, the term “security” or “securities” is not defined for the purposes of paragraph 20(1)(bb). ... Finally, we note that even if a segregated fund policy were considered a security for purposes of paragraph 20(1)(bb), it is not clear that the other conditions in that paragraph would be met in order to ensure deductibility of fees paid by investors for advice and services relating to their segregated fund policies. ...

Therefore, for supplies to be considered consumed directly in the performance of employment duties, the supplies must be used up and play an integral and essential part in the performance of the employment duties. ... Based on the above, cellular minutes and data would be considered “supplies that were consumed directly” where it is determined that the cellular minutes and data were used up and played an integral and essential part in the performance of the employment duties. ...

Therefore, for supplies to be considered consumed directly in the performance of employment duties, the supplies must be used up and play an integral and essential part in the performance of the employment duties. ... Based on the above, cellular minutes and data would be considered “supplies that were consumed directly” where it is determined that the cellular minutes and data were used up and played an integral and essential part in the performance of the employment duties. ...