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The determination of whether a particular prize is considered "a prize for achievement in a field of endeavour ordinarily carried on by the taxpayer" is a question of fact. ...

Generally speaking, when an employee maintains membership in a particular organization because of a legal requirement or because of a job requirement, such as a specification contained in a classification standard or in a job description, the payment or reimbursement of reasonable membership fees by the employer would not be considered to be a taxable benefit to the employee. ...

In this regard, the policy is an administrative accommodation, which under certain circumstances permits the fees to be considered to be the income of a partnership or corporation and not that of the individual director. ...

Because this amount would be considered a refund of premiums, the Guide directs that such payments be reported in Box 18 of the T4RSP. ...

Factors to be considered in making a determination include the purchase agreement, registration, taxpayer representations and identification of the person(s) who paid for the property. ...

XXXXXXXXXX 2006-018776 Joy Bertram January 16, 2007 Dear XXXXXXXXXX: Re: Meal Reimbursement Policy We are writing in response to your letter of May 23, 2006, wherein you requested our opinion on whether certain reimbursements or employer payment for meals are considered taxable benefits of employees under section 5 or 6 of the Income Tax Act (the Act). ...

" It is commonly accepted by the courts that an amount paid as damages for the breach of an employment contract is considered to be a retiring allowance. ...

The Agreement also provided that, should the Taxpayer be unable or unwilling to fulfil his return of service obligations, he would be required to pay back the full amount received under the Agreement, and it also provided that the financial support would be considered employment income. ...

Reasons: ITA XXXXXXXXXX 2006-018747 Joy Bertram January 14, 2007 Dear XXXXXXXXXX: Re: Financial Assistance to International and Aboriginal Students- Paragraph 56(1)(n) We are writing in response to your e-mail of May 19, 2006, wherein you requested our opinion on whether certain financial assistance paid to International and Aboriginal students as directed by donors is considered taxable income to the students under the Income Tax Act (the Act) and whether T4A's should be issued to those students. ...

We are writing in response to your letter of February 15, 2006, wherein you requested our opinion on whether certain payments and benefits received by you for performing services as a priest are considered taxable income and whether you are an employee or self-employed. ...