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8 April 2011 Internal T.I. 2011-0395571I7- Special Workplace Designation Unedited CRA Tags 6(6) Principal Issues: Whether certain employment would be considered employment at a special work site for purposes of subsection 6(6) of the Income Tax Act. ... However, as a general rule, duties will be considered to be of a temporary nature if it can reasonably be expected that they will not provide continuous employment beyond a period of two years. ...

Government grants and bonds are not considered to be connected to a reserve. (2) Depends on whether the income-generating activities of the issuer occur on a reserve; likely they do not. ... Consequently, these grants or bonds would not have sufficient connection to a reserve to be considered to be situated on a reserve, and would be included in income and subject to tax when received by an Indian beneficiary from the RDSP. ...

Although the May XXXXXXXXXX, 1997 court order indicated that the reduction of payments was effective from March 1st, 1997, it did not contain a provision providing that an amount paid before the court order was made is to be considered to have been paid thereunder. ... Finally, under certain circumstances described in subsections 56.1(3) and 60.1(3), a written agreement or court order made after April 1997 could be considered to have been made prior to May 1997 and subject to the old rules. ...

To be considered nominal, the compensation paid to the volunteer must generally be significantly less in comparison to what it would have cost to have the same duties performed by a regular employee or independent contractor. ... The value of the total compensation received by the volunteer on an annual basis should also be considered when determining if the amount is nominal. ...

Further, paragraph 251(2)(a) provides that individuals who are connected by blood relationship, marriage or common-law partnership or adoption are considered, for purposes of the Act, to be persons who are related to each other Subsection 160(2) is the authority to issue the assessment against the transferee, and provides that it may be raised at any time. ... A payment by one party that reduces the principal amount of a mortgage owing by another party is considered a transfer of property, albeit indirect, for purposes of subsection 160(1) (see Medland v. ...

It is a question of fact as to whether the payments received for the attendant care of an injured spouse can be considered income from employment or business (i.e. as a self-employed individual) in accordance with paragraph 3(a) of the Act. ... Generally, such arrangements do not have the requisite element of compensation to be considered income for tax purposes. ...

Generally, financial assistance provided to a student is considered a scholarship if provided by an educational facility. If the financial assistance is considered a repayable award received for educational purposes, the amount would be included in income pursuant to subparagraph 56(1)(n) or 56(1)(o) of the Act. ...

The definition of a QSBCS contains three main tests that must be met before the individual's shares can be considered as being QSBCS for these purposes. ... If the particular corporation itself has sufficient eligible assets described in (i) above to meet the 50% Holding Period Asset Use Test in paragraph (c) then the more stringent 90% Holding Period Asset Use Test described in paragraph (d) of the definition of QSBCS would not have to be considered. ...

Based on paragraph 7 of IT-339R2, an arrangement where an employer reimburses its employees for the cost of medical care or hospital care may be considered a PHSP where the employer is obligated under the employment contract to reimburse such expenses incurred by the employees or their dependants. The consideration given by the employee is considered to be the employee's covenants as found in the collective agreement or in the contract of service. ...

.), an insurance corporation that carries on business in Canada, including one described in paragraph 149(1)(t) of the Act, is considered a "financial institution" pursuant to paragraph (b) of that definition in subsection 181(1) of the Act. ... Section 142.5 of the Act generally requires a taxpayer that is a financial institution to annually recognize the appreciation or reduction in value of securities that are considered "mark-to-market property" as defined in subsection 142.2(1) of the Act. ...