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Imputed salary or remuneration will not qualify since no actual payment is made Finally, as discussed with you (XXXXXXXXXX/Mondou) concerning the deduction for the cost of full-time care in a nursing home under either paragraph 118.2(2)(b) or (d) of the Act, while we accept that a particular place does not necessarily need to be licensed as a nursing home in order to be considered as such, it must have sufficient staff to operate as a nursing home. ...

Principal Issues: Deduction of travel expenses of employee while on training, whether ‘ordinarily required to carry on duties of employment away from the employer’s place of business’; application of Tremblay decision Position: Department’s position to restrict application of Tremblay decision to identical facts Reasons: Decision based on facts of case and not considered precedent setting. ...

Our Comments We agree that your situation is very similar to the fact situation considered in the Schwartz case. ...

The Department had considered a general remission order with respect to benefits received from employers in respect of damages from the ice storm. ...

While paragraphs 118.2(2)(b) and (d) Income Tax Act (the “Act”) allow as a medical expense the cost of full-time care in a nursing home, it is the position of this Department that a particular place does not necessarily need to be licensed as a nursing home in order to be considered as such; however, it must have sufficient staff to operate as a nursing home. ...

Considered in the development of the bulletin position was the fact that the decision to distribute the income to the income beneficiary and to have the tax paid at the trust level, rather than the beneficiary level, should protect the capital beneficiaries from the adverse effect of the trust paying the tax. ...

Paragraph 22 of Information Circular 70-6R3 states that situations that involve completed transactions are considered by the Tax Services Offices. ...

It would be a question of fact whether or not other amounts transferred to an FRA would be considered to be from a US retirement or pension plan. ...

Where an amount is computed by the application of a rate of interest to payments made in advance of the due date such as property taxes levied by municipalities, the reduction is not considered interest, but rather a reduction of the amount otherwise payable. ...

Since the gross revenue test in subparagraph (vi)(A) of the definition of “qualified farm property” in subsection 110.6(1) of the Act has not been met in either situation 1 or 2, the farm properties would not be considered “qualified farm property” as defined in subsection 110.6(1) of the Act. ...