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The Directorate stated: [B]ased on the terms of the Payment Agreements … Canco agrees to make advanced payments to NR that are set off or deducted from the amount due by Canco to NR required under the Initial Contract. ... As such, the nature of the payments is different from [those] … in … 2008-29716 …. ... Accordingly … the advance payments made by Canco to NR under the Payment Agreements are subject to the withholding requirements of section 105 …. ...

. … Furthermore … the favourable tax results … are similar … to those available under the employee stock option rules …. even though … the requirements of paragraph 110(d) or (d.1) are not satisfied. ...

For the latter amount to be accepted, it must be reasonable in amount, as to which the Directorate stated: Although the maximum amount provided for in paragraph 53(2)(e) … is $20,000, it is possible that, in similar cases, the Tribunal may award only a relatively small amount compared to this maximum. …[W]e have … asked … for information concerning … human rights at the provincial level. We found that … human rights tribunals in several provinces (some of which had a maximum limit for general damages of less than $20,000 and some of which had no maximum limit at all) generally only awarded amounts below the maximum limit for general damages. ...

We consider those benefits to be "social assistance benefits" …. … The benefits are not solely for the benefit of an Indian resident on a reserve and are therefore not personal property of an Indian resident on a reserve and are therefore not exempt from taxation under [the Indian Act]. ...

16 December 2019 Internal T.I. 2019-0816101I7- Loans from LTD Partnerships to LTD Partner-- summary under Paragraph 96(2.2)(c) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(2.2)- Paragraph 96(2.2)(c) validity of loan by Ontario LP to limited partner turns on Ontario law When asked whether loans by an Ontario limited partnerships to limited partners would be treated as a loan for purposes of s. 96(2.2)(c), the Directorate indicated that: The reference in s. 96(2.2)(c) to an “amount owing” by a partner to a partnership does not deem partner debts to be valid, but instead merely “suggests that the legislator believed that at least in certain jurisdictions, there could be a debtor and creditor relationship between a limited partner (debtor) and a limited partnership (creditor)” – for instance s. 60(1) of the Partnership Act (B.C.) ... Rye / Klein line of cases): It is well established at common law that a man cannot contract with himself and that a partner cannot contract with a partnership of which he is a member. ... Act providing: “A limited partner may loan money to and transact other business with the limited partnership ….”) – but indicated that the doubts expressed in 2016-0637341E5 as to whether it was possible under the civil law for a limited partnership to make loans to a limited partner were not meant to apply to Ontario limited partnerships. ...

The Directorate concluded: [W]here the installation of such equipment is provided for in the plans and specifications for the construction of a building and the installation is carried out at various stages of the building's construction … it would be difficult to conclude, for this type of contract, that the Taxpayer is not a subcontractor engaged in the construction of a building since those activities are part of the building's construction process. On the other hand … the manufacture and installation of kitchen equipment in buildings already constructed or inside various means of transportation do not constitute activities relating to the construction of a building …. … [T]he Taxpayer may avail itself of the progress method set out in Interpretation Bulletin IT-92R2, provided that title to the construction vests in the Taxpayer's client or in the owner of the building as the work progresses and, furthermore, that the manufacture and installation of the particular equipment are provided for in the plans and specifications for the construction of a building. ...

. … [W]e have assumed that the rental income is property income to the non-resident person rather than business income (in which case the rental income would not be subject to Part XIII tax but rather to Part I tax). … [T]he services provided by [the property manager] o the lessees do not appear to be sufficiently important to characterize the rents as business income (see … IT-434R and … Walsh … 65 DTC 5293 (Ex. ...

25 February 2002 Internal T.I. 2001-0114167 F- DOMMAGES- DISCRIMINATION-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) awards by human rights tribunals for pain and suffering re wrongful termination often are under $5,000 Regarding what portion a settlement of a claim made under the Canadian Human Rights Act should be treated as compensation for pain and suffering, CCRA indicated that it had not examined the awards pattern of the federal Human Rights Tribunal in this regard, but noted: Although the maximum amount provided for in paragraph 53(2)(e) … is $20,000, it is possible that, in similar cases, the Tribunal may award only a relatively small amount compared to this maximum. …[W]e have … asked … for information concerning … human rights at the provincial level. We found that … human rights tribunals in several provinces (some of which had a maximum limit for general damages of less than $20,000 and some of which had no maximum limit at all) generally only awarded amounts below the maximum limit for general damages. ...

Rye / Klein line of cases): It is well established at common law that a man cannot contract with himself and that a partner cannot contract with a partnership of which he is a member. ... Act: “A limited partner may loan money to and transact other business with the limited partnership … ” (i.e., s. 12 does not specifically refer to limited partner borrowings). ...

Regarding the first assumption, CRA stated: [T]he better position is that [s. 163(1)] does not apply where a taxpayer files T1 income tax returns simultaneously for a number of consecutive taxation years and the taxpayer's income tax returns for the earlier taxation years were filed in accordance with the provisions of the Act …. … [T]he CRA should not apply subsection 163(1) respecting Mr. Y's unreported income under the first scenario …. Regarding the second assumption, CRA stated: [I]f the failure to report an amount to be included in Mr. ...