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However, in general terms, if it is designed to cover reasonable out-of-pocket costs that the elected representative will incur for the accommodations, then it will likely be considered reasonable. ...

Our Comments Having considered the proposed employment conditions for XXXXXXXXXX, we determined that an advance income tax ruling would not be appropriate and are returning your $535 deposit under a separate cover. ...

Pursuant to subsection 4900(8) of the Regulations, where a trust that is governed by an RRSP holds an interest in a SBIT that holds a SBS, and a person who is an annuitant or beneficiary of the RRSP provides services to or for the issuer of the SBS, or to or for a person related to the issuer, and it can reasonably be considered that any amount received in respect of the SBS is on account, in lieu or in satisfaction of payment for the services, then the interest in the SBS will cease to be a qualified investment immediately before the amount is received. ...

Another point not explicitly considered in the CRA's analysis is the interaction between paragraph 87(2)(j.4) (which applies by virtue of paragraph 88(1)(e.2)) and paragraph 88(1)(c). ...

On the other hand, if the primary purpose of the award is to carry out research for its own sake (for example, to further knowledge in a particular field by discovering new facts, or by reinterpreting existing knowledge), the award is considered to be a research grant and is included under paragraph 56(1)(o). ...

Therefore, with respect to your inquiry, the specific lake on which a particular individual earned business income from fishing would have to be identified, and confirmation obtained from INAC as to whether that lake is considered to be part of a reserve, whether pursuant to the XXXXXXXXXX or otherwise. ...

Therefore, brokerage companies would generally be considered listed financial institutions, and consequently, their employees would not be entitled to claim the employee GST/HST rebate. ...

The Queen (2001 DTC 496), the Tax Court considered whether subsection 127(5) of the Act imposed an ordering provision on claims for ITC. ...

Our comments It is possible that the payment of the amount could be made under an agreement between an employer and a lawyer such that the amount paid will not be received or considered to be received by, or on behalf of, the employee. ...

IT-339R2, dated August 8, 1989, sets out the requirements that must be met in order for a plan to be considered a PHSP. ...