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X …. The Residence would therefore have been disposed of by [them to] Mrs. X …. Regarding the verbal agreement … it is up to the taxpayer to demonstrate the existence of such an agreement whose effect is to transfer the ownership of the Residence at a particular time other than on XXXXXXXXXX. If the taxpayers can provide evidence to you of that verbal agreement, you should consult … Legal Services …. ...

. … Example 2 … Mr. A is present in Canada for 212 days in 2015, and the income of the partnership derived from his services is more than 50% of the gross active business revenue of the partnership ($200,000 / $350,000 = 57.14%) during those 212 days. ...

After noting that this structure appeared to be intended to maximize the small business deductions by the five managementcos, CRA stated: According … Hughes Homes … 98 DTC 1082 … taxpayers have the burden of demonstrating that the fundamental reasons for the existence of the corporations are not tax-related. … [I]t seems unlikely that the corporate structure was put in place by the Individuals for reasons other than tax: … an operating corporation is created and used for each of the projects involving a real business risk; the payment of management fees to the management corporations instead of the payment of dividends (if the Operator had paid dividends, the management corporations would have been specified investment business corporations); … 4 out of 5 of the individuals are related by blood. ...

B cannot claim the children's amount in respect of any of her children since …she is not entitled to the wholly dependent person credit in respect of them and … none of the children ordinarily reside throughout the year with her and another parent. … [I]t is Mr. A who would be entitled to the child amount under paragraph 118(1)(b.1) for both children … since … he would be able to claim the wholly dependent person credit for his two children if paragraph 118(4)(a) did not apply to him for the year. … [U]nder paragraph 118(4)(a), Mr. A would not be able to claim the wholly dependent person credit in respect of more than one of his children …. ...

The Directorate responded: Since the lump sum in this case was not paid in lieu of amounts payable periodically as described in paragraph 22 of … IT-530R … that amount is not a support amount within the meaning of subsection 56.1(4). ...

A taxable capital gain from the disposition of a "Canadian resource property" is therefore not included pursuant to subparagraph 115(1)(a)(iii) …. [Furthermore] … it is highly doubtful that the Right can be considered real property …. Article 900 of the Civil Code of Québec, which states that "fruits and other products of the soil may be considered to be movables … when they are the object of an act of alienation,” leads us to believe that the Right would not constitute immovable property but rather movable property. ...

After observing that “[p]rovincial income tax is not deductible … since … [it] is not an expense incurred for the purpose of gaining or producing income but rather is an expense incurred because income was earned,” CRA stated: Capital tax is not a tax that is calculated on the income of a business but rather a tax calculated on the paid-up capital of the corporation. ... The 1991Budget of the Department of Finance is consistent with this approach. … Interest on capital tax will be deductible if the capital tax is deductible by virtue of section 9. ...

18 May 2000 Internal T.I. 2000-0006037 F- FRAIS D'ACQUISITION-- summary under Timing; Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing commissions directly related to the acquisition of a life insurance policy are generally deductible in the year incurred Summary Under Tax Topics- Income Tax Act- Section 9- Timing commissions directly related to the acquisition of a life insurance policy are generally deductible in the year incurred CCRA indicated that “the matching principle mentioned in … IT-417R2 as well as the Agency's comments on the Canderel and Toronto College decisions set out in Income Tax Technical News No. 16 [and] … F9913160 … do not apply to acquisition expenses incurred by an insurer” (i.e., life insurance policy acquisition expenses, including commissions directly related to the acquisition of the policy) but indicated that generally, those expenses are deductible in the year in which they are incurred. ...

. … [T]he discharge from bankruptcy is not retroactive to the time the individual was declared bankrupt but … is effective from the date the proposal is approved by the court. … Although section 128 does not recognize proposals filed under the BIA, the discharge from bankruptcy [in] 2005 does not invalidate the filing and assessment of pre- and post-bankruptcy tax returns made prior to the date of discharge. … [T]he individual was bankrupt in the 2003 … 2004 … and the 2005 taxation year[s]. ... Since the approval of the proposal by the Court and the discharge of the individual's bankruptcy does not amount to an unconditional discharge under paragraph 128(2)(g) … we do not believe that this paragraph deems the unused portion of his tuition tax credits to be nil. Consequently, the individual may carry forward the unused portion of his or her tuition tax credits at the end of the 2005 taxation year … to the 2006 taxation year pursuant to section 118.61. ...

A copy of the amended T4 slips for a given taxation year must be sent to the … CRA … and all affected employees informing them that they may request an adjustment to their income tax return for the particular taxation year. ...