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Regarding when the amount of the credit reduced the ACB of the eligible investments pursuant to s. 53(2)(k), CRA stated: According to the CRA's longstanding position, a tax credit or reduction in the calculation of tax- which is not applied to reduce instalments payable by the taxpayer … is considered to have been received, where all the conditions for obtaining it have been satisfied, at the earliest of the following times: when it reduces the tax payable for a taxation year; at the time it is paid if it allows for or increases a tax refund. In view of the foregoing, where … a qualified investor attaches the prescribed Documents to the tax return that must be filed for a taxation year … in order to claim an amount in respect of the CSEQ, and the amount of the tax credit is less than the balance of tax payable for the year, the CRA is of the view that the CSEQ is received or is entitled to be received on the date of filing of the tax return. … … [T]he qualified investor will be entitled to receive the unused portion of the CSEQ … when the qualified investor files a carryover request, on the date the carryover request is filed. ...

. … Thus, the CRA considers that it is not possible to permit a member of a partnership to directly claim capital cost allowance for an eligible non-residential building, as this would be contrary to the rules respecting the computation of a partnership's income …. … [W]hen a partnership files a T5013 for its fiscal year, it must attach a letter indicating the election under ITR subsection 1101(5b.1). ...

11 October 2019 APFF Roundtable Q. 6, 2019-0812651C6 F- CDA and wind-up of a subsidiary-- summary under Paragraph 87(2)(z.1) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(z.1) IT-126R2 applicable in determining when CDA of sub is added to parent’s CDA Holdco, which has a calendar taxation year-end, commences the winding-up of its wholly-owned subsidiary (Opco – which has a June 30 taxation year-end) on March 31, 2018 with an authorizing resolution, and the Opco assets and liabilities are distributed and assumed on that date. ... CRA responded: [In] IT-126R2, the CRA states that it considers that where the formal dissolution of a corporation is not complete but there is substantial evidence that the corporation will be dissolved within a short period of time, for the purpose of subsections 88(1) and (2) the corporation is considered to have been wound up. … … The determination of when a corporation is wound up for the purposes of subsections 88(1) and 88(2) requires consideration of all facts and circumstances relevant to a particular situation. ...

. … [E]xpenditures in respect of research in determining economic viability may be considered to be on income account.... ... If so, it is denied current deduction …. … The postponement or cancellation of a project does not alter the nature of an expense incurred in connection with such project. ...

7 October 2022 APFF Financial Strategies and Instruments Roundtable Q. 2, 2021-0895981C6 F- Don d’une partie d’un intérêt dans une police d’assurance-vie en faveur d’un organisme de bienfaisance enregistré-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 148- Subsection 148(9)- Disposition implementing a life insurance interest sharing strategy may entail the entire policy’s disposition and uncertainties as to what interest is disposed of An individual owning a policy on that individual’s life with coverage of $1 million, a cash surrender value (“CSV”) of $250,000 and an adjusted cost basis ("ACB") of $150,000, donates ½ of the individual’s interest in the policy to a registered charity or, alternatively, only donates ½ of the entitlement to the CSV. ... CRA responded: [T]he donor will wish to ensure that a new policy is not created and that the portion of the policy the individual wishes to donate has been fully assigned in order to qualify for a donation tax credit. … … [I]t would be necessary to determine, i nter alia, whether the gift of a portion of the policy can be made without resulting, for the purposes of the applicable private law, in a disposition of the entire interest in the policy rather than just a portion of it. ...

. … Subject to certain exceptions under subsection 4(3) … subsection 4(2) … specifically denies the deduction of items in sections 60 to 64 … in determining income from a particular source. Consequently, a deduction allowed under paragraph 60(s) … is not tied to a particular source …. The amount determined under paragraph 3(c) … which forms variable F of the “non-capital loss” definition in subsection 111(8) … will never be negative, and therefore deductions described in Subdivision E of the Act cannot create or increase the amount of a non-capital loss. ...

. … … The Court concluded that the taxpayer would not have entered into the swaps if it had not acquired the US Operations. ...

Lola, 2013 SCC 5), it nonetheless “is not impossible for the annuitant to determine to create rights under a written separation agreement between the annuitant and the annuitant’s common-law partner or former common-law partner relating to the division of property ” – and that “such an agreement could be concluded at the time of separation, whether or not a common-law union agreement providing for the rights of each in the event of the union's failure had been previously signed.” ...

. … … It is CRA’s position that reforestation obligations in the forest industry and reclamation obligations in the mining and oil and gas industries are generally embedded in the related tenures or rights, as they cannot usually be severed and would therefore depress the value. ...

This Proof of Income can be viewed and printed by a taxpayer using the "My Account for Individuals" option …. … [W]ith respect to capital cost allowance that may have been claimed by a taxpayer in prior years, this information could possibly be included in the Proof of Income mentioned above. ...