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S4-F7-C1- Amalgamations of Canadian Corporations-- summary under Subsection 87(1.1) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(1.1) s. 87(1.1) qualifies for all s. 87 purposes 1.9 … Subsection 87(1.1) deems the shares that are not cancelled on a short-form vertical or horizontal amalgamation to be shares of the new corporation. ...

. … 1.47 …[T]he control of a particular corporation by a trust may also result in a trustee of the trust being related to the particular corporation because of that trustee's ownership of the shares of, and control of, the corporation. ...

In order to determine the tax treatment of an amount (for example, an art production grant), it must first be ascertained whether, for income tax purposes, it is properly characterized as income from business or property; income from an office or employment; a scholarship, fellowship, bursary, prize, research grant, financial assistance or something else …. ...

S4-F14-C1- Artists and Writers-- summary under Subsection 200(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 200- Subsection 200(2) Requirement to issue T4A even where amount exempt 1.74 Under subsection 200(2) of the Regulations, every payer of a research grant, scholarship, fellowship, bursary, or prize (other than a prescribed prize), must report the amount on a T4A … and the related T4A Summary. ...

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Required connection between move and employment/business/education 4.7 To satisfy the condition described in ¶ 4.3(a) or ¶ 4.4 (a), there must be a connection between the individual’s move and one of the following activities: carrying on a business or being employed at a location in Canada or attending an educational institution. ...

. … Comparison of resource and non-resource activities 1.11 A…corporation will generally qualify as a PBC if the corporation's activities of the kind described in [s. 66(15)] represent a larger or more important business operation than all other activities of the corporation combined…. 1.12 The following are important criteria for making [this] determination…: the amount of income derived from each business operation; the amount of gross revenue attributable to each business operation; the operating costs and expenses of each business operation; the capital employed in each business operation; and the time and effort expended by the employees on each business operation. ... For example, a mining corporation which has qualified as a PBC for many years might suffer a temporary decline in its mining activity in a particular year due to various problems, such as adverse economic conditions, labour problems, or other short-term difficulties. … [I]n determining whether a corporation qualifies as a PBC for a particular year, regard may be had to a future plan of the corporation to the extent that it is implemented in the year. ...

Two questions set out by the courts to determine whether such a connection exists for purposes of a retiring allowance are as follows: Question 1 – But for the loss of employment would the amount have been received? and Question 2 – Was the purpose of the payment to compensate a loss of employment? ...

S4-F14-C1- Artists and Writers-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose Examples of deductible expenses of an artist such as specialized wardrobe, lessons and PD and filming and recording costs for performance (but not for study purposes) 1.38 For artists and writers, examples of deductible expenses could include: insurance premiums on musical instruments and equipment; the cost of repairs to instruments and equipment, including the cost of new reeds, strings, pads, and accessories; legal and accounting fees; union dues and professional membership dues; an agent's or mandatary's commission; remuneration paid to a substitute or assistant; the cost of makeup and hair styling required for public appearances; publicity expenses consisting generally of the cost of having photographs taken and sent with a descriptive commentary to producers, presenters, and the media, and including the cost of advertisements in publications; transportation expenses related to an engagement (including an audition) in a situation where: the engagement is out of town, in which case, board and lodging would also be allowed (see Interpretation Bulletin IT‑518R, Food, Beverages and Entertainment Expenses), a large instrument or equipment must be carried to the engagement, dress clothes must be worn from a residence to the place of engagement, or one engagement follows another so closely in time that a car or taxi is the only means by which the engagement can be fulfilled; the cost of filming or recording performances where required for their preparation or presentation; telephone and cell phone expenses, including an applicable portion of the cost of a telephone in a residence where the number is listed as a business phone; capital cost allowance (CCA) (Class 8) on instruments, sheet music, scores, scripts, transcriptions, arrangements, and equipment; CCA (Class 8) on the cost of wardrobe items acquired by an artist specifically to earn self-employment income and that is used solely for performances, when the acquisition of such items gives rise to an enduring benefit to the artist …; the cost of wardrobe items used solely for performances when there is no enduring benefit to an artist; the cost of repairs, alterations, and cleaning of clothes for the purpose of their use in self-employment, or required as a result of such use; costs to maintain that part of an artist or writer's residence used for business purposes or to rent a studio; the cost of music, acting, or other lessons incurred for a particular role or part or for the purpose of general self-improvement in an individual's artistic field; the cost of industry-related periodicals; the cost of equipment rental; art shipping expenses; and the cost of professional development activities and specialized training. 1.39 The following deductions are not allowable because they are either capital expenditures or they are personal or living expenses: the cost of musical instruments or other equipment necessary for the artist's performance (however, CCA may be deducted …); the cost of sheet music, scores, scripts, transcriptions, arrangements, other recordings, or "air checks" (again, however, see the comments in ¶1.38(l) regarding CCA); filming and recording costs incurred specifically for the purpose of study and general self-improvement (however, if the preparation or presentation of a particular performance requires that it be filmed or recorded, see ¶1.38(j)). ...