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Other Information To the best of your knowledge, none of the issues involved in this advance income tax ruling is: a. in an earlier Canadian return of a person related to LLC; b. being considered or under assessment by a Canadian tax services office or taxation centre in connection with a previously filed Canadian tax return of a person related to LLC; c. under objection by LLC or a person related to LLC; or d. before the courts, and no judgment has been issued which may be under appeal. ...

Consider the following scenario: A father owns a life insurance policy under which both his son and daughter-in-law (who is considered a child under the extended definition of child in subsection 252(1)) are the lives insured. ...

For example, courses of a personal nature or which develop technical skills that are not related to the employer's business are considered to primarily benefit the employee. ...

Note that external publications support that it not absolutely necessary that all property of a charitable corporation be considered to be held in trust (although the presumption would be that it held in trust) May 19, 2004 International Tax Services Office HEADQUARTERS T3 Non-Resident Trust Section Annemarie Humenuk Attention: Rose Wilcox 2004-005649 XXXXXXXXXX This is in response to your memorandum of January 13, 2004, in which you ask whether the above noted foundation is a trust or a corporation. ...

30 June 2004 External T.I. 2004-0073351E5- 97(2) and Retired partners Unedited CRA Tags 97(2) 96(3) Principal Issues: Are retired partners considered members of a partnership for purposes of 97(2)? ...

A designation under subsection 104(22) deems the beneficiary's income that would otherwise be considered the beneficiary's income from a trust resident in Canada to be the beneficiary's income from the particular foreign source for the purposes of subsections 104(22) and 104(22.1) and section 126. ...

The Top-Up amount will be considered to have been received by the Participant in respect of employment exercised in Canada to the extent that it relates to Options granted to the Participant while he was employed in Canada. ...

As a general rule, an allowance will be considered reasonable if it is designed to cover an employee's out-of-pocket costs for the use of the motor vehicle during the course of performing the duties of employment. ...

Generally, travel between an employee's personal residence and the employer's place of business where the employee ordinarily reports for work is considered personal in nature. ...

When a scholarship or bursary is received by a status Indian, paragraph 81(1)(a) of the Income Tax Act and section 87 of the Indian Act may provide a tax exemption if the income is considered an Indian's personal property situated on a reserve. ...