Section 5

Subsection 5(1) - Income from office or employment

Commentary

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Cases

Pluri Vox Media Corp. v. Canada, 2013 DTC 5012 [at 5559], 2012 FCA 295

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The Queen v. Conseil central des syndicats nationaux du Saguenay/Lac St-Jean (Csn) et al., 2010 DTC 5038 [at 6665], 2010 FCA 375

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Kilbride v. Canada, 2009 DTC 5502, 2008 FCA 335

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Merchant v. The Queen, 2009 DTC 282, 2009 TCC 31

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) advance is current remuneration if repayable only out of future earnings 131

Eaton v. Canada, 2008 DTC 6395, 2008 FCA 162

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Messier v. The Queen, 2008 DTC 4609, 2008 TCC 349 (Informal Procedure)

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Dupuis v. Canada (Canada Revenue Agency), 2007 DTC 5106, 2006 FC 228

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Morency v. Canada (Attorney General), 2006 DTC 6069, 2005 FCA 16

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Royal Winnipeg Ballet v. Canada (Minister of National Revenue), 2006 DTC 6323, 2006 FCA 87

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Tax Topics - General Concepts - Agency 78

Mollinaro v. The Queen, 2000 DTC 6114 (FCA)

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The Queen v. Blanchard, 95 DTC 5479 (FCA)

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Words and Phrases
remuneration

R. v. Gentile, 95 DTC 5176 (Ont. Ct. J. (P.D.))

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Attorney General of Canada v. MacDonald, 94 DTC 6262 (FCA)

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Words and Phrases
remuneration

Sutherland v. The Queen, 91 DTC 5318 (FCTD)

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The Queen v. Fairey, 91 DTC 5230 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) 78

The Queen v. Chrapko, 88 DTC 6487, [1988] 2 CTC 342 (FCA)

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The Queen v. Kurisko, 88 DTC 6434, [1988] 2 CTC 254 (FCTD), aff'd 90 DTC 6376 (FCA)

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Moose Jaw Kinsmen Flying Fins Inc. v. MNR, 88 DTC 6099 (FCA)

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McNeill v. The Queen, 86 DTC 6477, [1986] 2 CTC 352 (FCTD)

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Marotta v. The Queen, 86 DTC 6192, [1986] 1 CTC 393 (FCTD)

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The Queen v. Hoffman, 85 DTC 5508, [1985] 2 CTC 347 (FCTD)

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The Queen v. Manley, 85 DTC 5150, [1985] 1 CTC 186 (FCA)

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The Queen v. Pollock, 84 DTC 6370, [1984] CTC 353 (FCA)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Stare Decisis 60
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base cost incurred to acquire right to receive damages 58

Lawson v. The Queen, 82 DTC 6331, [1982] CTC 368 (FCTD)

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Jack Cewe Ltd. v. Jorgenson, 80 DTC 6233, [1980] CTC 314, [1980] 1 S.C.R. 812

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Dauphinee v. The Queen, 80 DTC 6267, [1980] CTC 332 (FCTD)

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Brackstone v. The Queen, 80 DTC 6060, [1980] CTC 89 (FCTD)

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Boardman v. The Queen, 79 DTC 5110, [1979] CTC 159 (FCTD)

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Gahrns v. The Queen, 78 DTC 6436, [1978] CTC 651 (FCTD)

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Tax Topics - General Concepts - Evidence taxpayer able to contradict his receipt 47

Loeb v. The Queen, 78 DTC 6331, [1978] CTC 460 (FCA)

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Frappier v. The Queen, 76 DTC 6066 (FCTD)

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The Queen v. Atkins, 76 DTC 6258, [1976] CTC 497 (FCA)

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Tax Topics - Income Tax Act - Section 3 7

The Queen v. Burns, 73 DTC 5219, [1973] CTC 264 (FCTD)

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) 24

See Also

6094350 Canada Inc. and Genex Communications Inc.v. Agence du revenu du Québec, 2018 QCCQ 556

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) tax advice that was based on clearly flawed factual assumptions could not be relied upon for defence 411
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) CRA treatment of taxpayer’s players as independent contractors was not binding on the ARQ 88

Russell v. M.N.R., 2016 TCC 143

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Andrew Peller Limited v. M.N.R., 2016 DTC 1009 [at 2553], 2015 TCC 329

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Other locations for this summary
Tax Topics - Other Legislation/Constitution - Federal - Employment Insurance Act - Section 82 - Subsection 82(1) restaurant tips are remuneration from an employer
Tax Topics - Other Legislation/Constitution - Federal - Canada Pension Plan - Section 8 - Subsection 8(1) restaurant tips are remuneration from an employer
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Specific v. General Provisions use of "gratuities" in a specific provision did not imply that another kind of gratuity could not be caught under a general provision 220

Hines v. The Queen, 2016 DTC 1003 [at 2509], 2015 TCC 317

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Big Bird Trucking Inc. v. M.N.R., 2015 TCC 340

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Rogers Estate v. The Queen, 2015 DTC 1029 [at 124], 2014 TCC 348

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Words and Phrases
remuneration
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) cash surrender of employee stock options for their value was not shareholder benefit 116
Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) capital gain can arise from property which is not capital property 249
Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(a) s. 7 a complete code for taxation of stock option benefits 214
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Options holding one's employee stock options until just before they expire is not typical of an adventure in the nature of trade 171

McCormick v. Fasken Martineau DuMoulin LLP, 2014 SCC 39, [2014] 2 S.C.R. 108

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Tax Topics - Income Tax Act - Section 96 equity partner not an employee under (human rights) control and dependency test 158

1392644 Ontario Inc. (Connor Homes) v. Canada (National Revenue), 2013 FCA 85

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M.A.P. v. M.N.R., 2012 DTC 1112 [at 3065], 2012 TCC 70

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Chabaud c. La Reine, 2012 DTC 1076 [at 2856], 2011 TCC 438 (Informal Procedure)

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Follwell v. The Queen, 2011 DTC [at 1709], 2011 TCC 422 (Informal Procedure)

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Boisvert v. The Queen, 2011 DTC 1296 [at 1670], 2011 TCC 290

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Pluri Vox Media Corp. v. The Queen, 2011 DTC 1175 [at 960], 2011 TCC 237 (Informal Procedure), aff'd on different reasoning, supra

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Sochatsky v. The Queen, 2011 DTC 1065 [at 346], 2011 TCC 41, 2012 TCC 65

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt bonus booked as loan back/constructive receipt 129
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) 162

MacIntyre v. The Queen, 2010 DTC 1053 [at 2801], 2010 TCC 27 (Informal Procedure)

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Ganpaul v. The Queen, 2009 DTC 731, 2009 TCC 205 (Informal Procedure)

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Merchant v. The Queen, 2009 DTC 282, 2009 TCC 31

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Words and Phrases
loan
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 131

Ville de Québec v. The Queen, 2008 DTC 4967, 2007 TCC 329

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Carreau v. The Queen, 2008 DTC 3106, 2006 TCC 20

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Lockhart v. The Queen, 2008 DTC 3044, 2008 TCC 156

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Lang v. M.N.R., 2007 DTC 1754, 2007 TCC 547

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Suspended Power Lift Service Inc. v. The Queen, 2007 DTC 1505, 2007 TCC 519 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) withholding triggers remittance obligation 60

Maliyar v. The Queen, 2007 DTC 337, 2006 TCC 671 (Informal Procedure)

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Pellerin c. La Reine, 2006 DTC 3341, 2006 TCC 383 (Informal Procedure)

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DRL Group Ltd. v. M.N.R., 2006 DTC 3113, 2006 TCC 331

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Algoma Taxicab Management Ltd. v. M.N.R., 2006 DTC 2497, 2006 TCC 71

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Foley v. The Queen, 2006 DTC 2281, 2006 TCC 55 (Informal Procedure)

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Au v. The Queen, 2005 DTC 794, 2005 TCC 303

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McLean v. The Queen, 2004 DTC 2585, 2004 TCC 200 (Informal Procedure)

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Preddie v. The Queen, 2004 DTC 2427, 2004 TCC 181 (Informal Procedure)

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Shaw Communications Inc. v. MNR, 2003 DTC 1459 (TCC), aff'd 2003 DTC 5707 (FCA)

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Dion Neckwear Ltd. v. Christian Dior SA (2002), 215 DLR (4th) 413, 2002 FCA 29

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671122 Ontario Ltd. v. Sagaz Industries Canada Inc., [2001] 2 S.C.R. 983, 2001 SCC 59

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Baptist v. The Queen, 2000 DTC 2045 (TCC), briefly aff'd 2001 DTC 5574 (FCA), 2001 FCA 298

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Saardi v. The Queen, 99 DTC 767 (TCC)

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Gernhart v. The Queen, 96 DTC 1672 (TCC), briefly aff'd 98 DTC 6026 (FCA), Docket: A-625-96

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) tax equalization payment 69

Phillips v. The Queen, 95 DTC 194 (TCC)

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Tax Topics - General Concepts - Payment & Receipt book entry did not give rise to receipt 91

Meredith v. The Queen, 94 DTC 1271 (TCC)

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Hall v. Lorimer, [1993] BTC 473 (C.A.)

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Shilton v. Wilmshurst, [1991] BTC 66, [1991] UKHL TC_64_78 (HL)

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Head and Head Holdings Ltd. v. Intertin Canada Ltd. (1991), 5 OR (3d) 192 (Ont. Ct. G.D.)

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McMenamin v. Diggles, [1991] BTC 218 (Ch. D.)

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Wiebe Door Services Ltd. v. MNR, 87 DTC 5025, [1986] 2 CTC 200 (FCA)

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Canadian Pacific Ltd. v. A.G. (Can.), [1986] 1 S.C.R. 678.

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Narich Pty. Ltd. v. Commissioner of Pay-roll Tax, [1984] BTC 8019 (PC)

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Tax Topics - General Concepts - Payment & Receipt indirect receipt of wages 28

Sazio v. MNR, 69 DTC 5001 (Ex Ct)

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) 159

Administrative Policy

28 July 2017 External T.I. 2017-0685961E5 - Taxation of Settlement Amounts

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance settlement amount (re post-retirement benefits reduction) also paid to current employees likely not retiring allowance 163
Tax Topics - Income Tax Act - Section 6 - Subsection 6(3) - Paragraph 6(3)(b) settlement amounts paid after repudiation of post-retirement health benefits were deemed employment income 222

21 July 2017 Internal T.I. 2017-0714931I7 F - Retiring allowance - Sick Leave

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance payout of accumulated (non-excess) sick leave credits on termination of employment was a retiring allowance 159
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Death Benefit includes payout on death of accumulated (non-excess) sick leave credits 178

19 December 2016 External T.I. 2016-0643191E5 F - Deferred Salary Leave Plan (DSLP)

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Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(n) deduction where “repayment” of advances made during employee leave 211
Tax Topics - Income Tax Regulations - Regulation 6801 - Paragraph 6801(a) comprehensive discussion, including: seasonal workers cannot participate; and DSLP can be married with a salary advance arrangement 436

6 June 2016 Internal T.I. 2015-0590411I7 F - Revenu d’emploi ou allocation de retraite

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance “salary” paid after employment duties had ceased was retiring allowance 570

26 April 2016 Internal T.I. 2015-0623571I7 - one-time salary transition payment

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Words and Phrases
advance
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(n) deduction for repayment of transitional advance 155
Tax Topics - Income Tax Act - Section 80.4 - Subsection 80.4(1) employee advance not a “loan” 115

2015 Ruling 2014-0542411R3 - Carrying on business in Canada and PE

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Tax Topics - Treaties - Income Tax Conventions - Article 5 PE in Canada of ForCo avoided through seconding employees to its Cdn sister and meeting in Canada up to 90 days annually only offsite 513
Tax Topics - Income Tax Regulations - Regulation 102 payroll reimbursement payments under employee secondment arrangement not subject to Reg. 105 199
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) no mark-up on cross-border payroll reimbursement represented to accord with s. 247 101

12 February 2015 External T.I. 2014-0550771E5 F - Allocation à des bénévoles - chantier particulier

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Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts mission work volunteers foregoing allowances 96
Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit modest compensation to volunteers qua independent contractors not income 98
Tax Topics - Income Tax Act - Section 6 - Subsection 6(6) mission work under 2 years in LDCs 97

S2-F3-C1 - Payments from Employer to Employee

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S3-F9-C1 - Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime

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10 April 2013 Internal T.I. 2013-0475991I7 F - Montant- période de raccordement

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13 February 2013 External T.I. 2012-0448621E5 - Employee Referral Fee

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6 November 2012 External T.I. 2012-0455951E5 - Flexible Benefits

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29 March 2012 Internal T.I. 2011-0430871I7 F - Participation à une étude de recherche clinique

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5 January 2011 External T.I. 2008-0305252E5 - Taxation of Post-Doctoral Fellowships

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30 September 2010 External T.I. 2010-0376881E5 - Board Member Fees

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2001 Ruling 2001-009074 -

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10 April 2001 External T.I. 2001-007123 -

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1 March 1999 T.I. 982169

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2 July 1998 T.I. 980455

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1998 Revenue Canada Paper 9824890

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11 October 1994 Memorandum 941816

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10 August 1994 Internal T.I. 7-941932 -

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18 July 1994 External T.I. 5-941078 -

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26 May 1994 Memorandum 933331

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10 February 1994 Internal T.I. 7-931630 -

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25 March 1992 T.I. (Tax Window, No. 18, p. 18, ¶1829)

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21 November 1991 Memorandum (Tax Window, No. 13, p. 4, ¶1606)

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30 August 1991 T.I. (Tax Window, No. 8, p. 16, ¶1428)

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15 May 1991 Speech of B.W. Dath (Tax Window, No. 3, p. 7, ¶1257)

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IC 75-6R2 "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada," para. 66

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CRA Guide, RC4110, "Employee or Self-Employed?"

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Dov Begun, "Equity Based Compensation and Stock Options", 2017 Annual CTF Conference draft paper

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Gael Melville, Lucie Champagne, Yves Plante, "Tax Considerations for the Newly-Self-Employed", 2011 Canadian Tax Journal, Vol 59, p. 843

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(12) 9

Worndl, "Employee or Independent Contractor - Some Guidelines", Tax Profile, Vol. 3, No. 36, June 1993, p. 324.

Baston, "Tax Planning for Executive Hiring and Firing", 1991 Corporate Management Tax Conference Report, c. 10.

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Wilson, "Employment Status under the Income Tax Act", 1991 Corporate Management Tax Conference Report, c. 2

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Subsection 5(2) - Loss from office or employment

Administrative Policy

11 April 2001 External T.I. 2000-007322 -

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