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This will result in the loss of treaty benefits, as follows: any income accrued in the Roth IRA after the Canadian Contribution will cease to benefit from the deferral of taxation afforded by the Election and thus becomes subject to Canadian taxation on a current, annual basis as outlined in ¶ 1.3 to 1.7; any income accrued in the Roth IRA before the first Canadian Contribution will continue to be eligible for tax deferral afforded by the Election; and distributions from the Roth IRA will continue to be exempt from taxation to the extent of the balance in the Roth IRA immediately before the first Canadian Contribution. 1.13 Effectively, a Canadian Contribution splits a Roth IRA into two parts – one part consisting of the balance in the Roth IRA immediately before the Canadian Contribution and the other part consisting of the Canadian contribution (and any subsequent contributions) and all income accrued in the Roth IRA after the Canadian Contribution. ...

. … 1.44 Partners are not necessarily considered not to deal at arm's length with each other in transactions outside of their partnership activity merely because they are members of the same partnership Shareholders acting in concert 1.53 …[I]f a sufficient number of minority shareholders act in concert in order to direct the affairs of a corporation, they may be considered not to be dealing at arm's length with the corporation. … In a widely-held corporation, the fact that a majority of shareholders vote collectively to take some business action may not, by itself, indicate that those shareholders are acting in concert…. 1.54 [In] situations where closely-held private corporations employ some of the same personnel, occupy the same premises, and to the public eye, appear to be one enterprise…the corporations may be considered not to be dealing with each other at arm's length. ...

This means that the years that the trust must include in variable C in the principal residence exemption formula in ¶ 2.17- 2.26 are 1995 to 2011 inclusive. ... The trust cannot designate the house as its principal residence for the years 1995 to 2004 inclusive; however, such a designation by the trust is not necessary – the house is already deemed by subsection 40(4) to have been the trust’s principal residence for those years, in accordance with the rule described in ¶2.70(b) above, because Mr. ...

S3-F3-C1- Replacement Property-- summary under Paragraph 44(5)(b) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(5)- Paragraph 44(5)(b) Meaning of similar business 1.41 The term similar business as used in the phrase “the same or a similar business” or “from that or a similar business” in ¶ 1.33(c) is generally interpreted in a reasonably broad manner. ...

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. … Capital loss on demolished building 1.83 If a building is demolished without being used for the purpose of gaining or producing income, it would likely not be depreciable property in the purchaser's hands by reason of paragraph 1102(1)(c) of the Regulations. ...

S3-F4-C1- General Discussion of Capital Cost Allowance-- summary under Subsection 43(1) Summary Under Tax Topics- Income Tax Act- Section 43- Subsection 43(1) Non-pro-rata apportionment 1.77 … [T]he pro rata apportionment of the capital cost of a depreciable property would not be reasonable in all circumstances. ...

S3-F4-C1- General Discussion of Capital Cost Allowance-- summary under Section 68 Summary Under Tax Topics- Income Tax Act- Section 68 Categories covered 1.80 … As it pertains to depreciable property, the provisions of section 68 can apply to consideration for: both depreciable and non-depreciable property; depreciable properties included in two or more prescribed classes; or depreciable property and something other than property, such as services, or a restrictive covenant as defined in subsection 56.4(1). ...

The maximum that Jacques can contribute to his RRSP and claim a deduction under paragraph 60(j.1) is $27,000: $2,000 x 12 full or partial years before 1996 plus $1,500 x 2 years before 1989 with no vested benefits $24,000 $ 3,000 Maximum deduction $27,000 During 2016, Jacques contributes $35,000 to his RRSP. ...

S3-F9-C1- Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Timing timing of deduction for loss from theft or embezzlement 1.38 … In cases where the allowable loss is already reflected in the reported income or loss of a business, the amount of reported income or loss will not have to be adjusted. ...