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Depending on the nature of the payment and the arrangements or circumstances under which it is made, a payment may be considered: (a) income from business; (b) income from an office or employment; or (c) a scholarship, fellowship, bursary, prize or research grant. ... Accordingly, the Payment is not considered income from an office or employment. ...

Where the shareholder receives a loan from the corporation, the amount of the loan is considered to be a benefit and is included in computing the shareholder's income for the year under subsection 15(2), unless one of the exceptions in subsection 15(2.4) applies. ... Generally, a benefit will be considered to be conferred qua employee if it is reasonable to conclude that a benefit is conferred on an individual as part of a reasonable employee remuneration package. ...

With respect to respite care, since it is provided on a temporary or short term basis, it is our view that the cared-for individual could not be considered to be residing in the respite care provider's principal place of residence. Similarly, the respite care provider's residence would not be considered to be maintained as the cared-for individual's residence. ...

Where the whole course of conduct indicates that (a) in security transactions the taxpayer is disposing of securities in a way capable of producing gains and with that object in view, and (b) the transactions are of the same kind and carried on in the same way as those of a trader or dealer in securities, the proceeds of sale will normally be considered to be income from a business and, therefore, on income account. ... Where you participate in currency futures activities on a full-time basis, we would generally view the gains and losses to be considered on account of income, regardless of whether the investing activities are transacted personally or through a corporation. ...

" The term "damages" is defined in paragraph 2 of IT-467R2, which states that "A payment in settlement of a damages claim to avoid or terminate litigation will be considered "damages" for the purposes of this bulletin, even where there was no admission of any wrongdoing. ... X to remove her lien against your property is considered a cost incurred in making the disposition and should be added to the adjusted cost base of your property for the purpose of determining the capital gain from your property disposition. ...

Is a Hairstylist considered a "tradesperson" for purposes of paragraph 8(1)(s) of the Act such that he/she is entitled to deduct the cost of "eligible tools" purchased in the year under paragraph 8(1)(s) of the Act? ... A hairstylist is considered a "tradesperson" in Canada. XXXXXXXXXX 2008-029119 Renee Sigouin (613) 957-2128 January 9, 2009 Dear XXXXXXXXXX: Re: Employment Expenses- Hairstylist We are writing in response to your letter of August 28, 2008 wherein you requested our comments regarding the deductibility of certain expenses incurred by a hairstylist and her employer's obligation to complete and sign a Form T2200- Declaration of Conditions of Employment in relation to these expenses. ...

You have asked us to confirm your view that the quantum of such indebtedness to be considered at the end of each year for purposes of the definition of "tax shelter" in subsection 237.1(1) of the Act would be limited to the unpaid balance expected to be outstanding at the end of that particular year. ... Generally, an interest in a partnership would be a tax shelter, as defined in subsection 237.1(1) of the Act, if, inter alia, statements or representations have been made regarding tax losses expected to be allocated to a hypothetical purchaser, as a result of acquiring the partnership interest, where it can reasonably be considered that at the end of any taxation year that ends within four years after the day on which the purchaser acquires the property [that 4-year period being referred to in this letter as the "Calculation Period"], (i) the total amount of the partnership losses represented to be deductible by the purchaser in the year or any preceding year, would equal or exceed (ii) the amount, if any, by which the purchaser's cost of the partnership interest at the end of that year would exceed the total of all amounts each of which is the amount of any "prescribed benefit" that is expected to be received or enjoyed, directly or indirectly, in respect of that partnership interest by the purchaser or another person with whom the purchaser does not deal at arm's length. ...

Under your facts since Hong Kong does not have a tax treaty with Canada, whether or not the Corporation or the Shareholder is considered resident in Hong Kong under common law principles, will not in and of itself affect the application of the deeming provision in subsection 250(4) of the Act. ... Since the Corporation and the Shareholder are incorporated in Canada, they are both resident in Canada pursuant to paragraph 1 of Article IV; however, by virtue of some other criterion referred to above, such as the place of management, it may be possible that each is also prima facie considered resident in the United States. ...

The late filing penalty is calculated on tax payable first, before a future tax consequence is considered. ... However, when future tax consequences, such as a loss carryback, are considered, the Minister has to determine the person's tax payable for the year before considering the effect of such tax consequences: subsection 162(11of the Act. ...

Meal expenses Although meals are generally considered to be a personal or living expense, paragraph 18(1)(h) of the Act identifies an exception to this rule with respect to travel expenses incurred by a taxpayer while away from home in the course of carrying on the taxpayer's business. In other words, even though meals or accommodation would normally be considered a personal or living expense, paragraph 18(1)(h) of the Act permits a deduction for such expenses if they are incurred for the purpose of earning income from business and while away from home in the course of carrying on that business. ...