Principal Issues:
calculation of part F of the formula for a non-capital loss where taxpayer has both income and a loss from a particular type of income (i.e. rental, farming, business, professional) as well as subdivision e deductions in excess of the total amount of income from all sources
Position:
income and losses from different sources of employment, business, property, etc. should be determined separately so that the amount of income shown on form T1A is not netted by any losses from a source
Reasons:
if income from all sources is computed with reference to the net amounts shown on the T1 return and is less than the total of subdivision e deductions, then the total losses will be understated as so will the non-capital loss