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The Directorate noted that the relevant BC ITA provisions were modeled on ITA s. 125.4(1) – labour expenditure – (b)(iii) and s. 125.5(1) – Canadian labour expenditure- (b)(iii). In finding that this shareholding satisfied the above “belong to” test, rather than the shares belonging to the trust under the position of the TSO, the Directorate stated: [T]he shares … belong to [the individual] and not the Trust for purposes of the tax credit. ...

CRA stated: Since the date of the cancellation of Interpretation Bulletin IT-265R3, there have been no legislative changes or court decisions reversing … [CRA’s] position …. As a result, we are of the view that paragraphs 8 to 10 [thereof] … still represent the CRA's position with respect to deferred or instalment payments. ...

The CRA accepts that, pursuant to the tax relief measure described in paragraph 7 of Article XXI … a gift made by a Canadian resident to a U.S. 501(c)(3) organization will be an eligible gift for purposes of the deduction in computing taxable income under section 110.1 …. or a non-refundable tax credit … under section 118.1 … subject to the income limitations, described in those sections, from U.S. sources. ... [S]ince subsections 149.1(2), (3) and (4) … govern the revocation of a charity’s registered status, and not the imposition of taxes, the Canada-U.S. ... Accordingly … Article XXI[(7)] of the Canada-U.S. Treaty does not deem a U.S. 501(c)(3) organization to be a qualified donee, for purposes of subsections 149.1(2), (3) and (4) …. ...

With respect to the use test in subparagraph 110.6(1.3)(c)(ii), … IT-373R2 … states that the criterion that an asset must be used "principally" in the course of carrying on the business of farming is satisfied if more than 50% of the asset’s use is actually for that business. ...

. … However … where salary and wages are only reflected by journal entry as an expense by the employer with a corresponding credit to a due to shareholder loan account, such salary and wages are not considered eligible remuneration paid to an eligible employee for purposes of subsection 125.7(2). ...

. … Any notification sent to the partnership in this circumstance would merely be an acknowledgement that the information has been received and recorded. However, the Minister may use the information contained in the amended T5013 to reassess one or more of the partners provided that the taxation year of the particular partner or partners is not statute-barred. … [T]he Minister may reassess the return of income of a member of a partnership without making a determination of the partnership under subsection 152(1.4) of the Act provided the partner’s particular taxation year is not statute-barred. … Accordingly … the Minister had the authority to issue the reassessment for Partner 2. ...

After finding that such amounts were not a reserve described in s. 181.2(3)(c), and in finding that they were includible in taxable capital pursuant to s. 181.2(3)(b) as “advances,” the Directorate stated: The word "advance" … denotes, inter alia, the lending of money or the payment of an amount against the price of a contract for services or goods, paid before the contract is performed, the services rendered or the goods delivered. … [I]n this context … the consideration to be received by customers is … the XXXXXXXXXX service offered by the corporation. ...

In computing Part XII.6 tax of the PBC for February to June 2020, it is deemed to have incurred $3M of CEE before the end of those months, so that the tax would be computing (applying the prescribed rate of 2%) in accordance with the formula: ($5M- $3M) X (0.02/12 + 0/10) = $3, 333.33 so that the tax for each month during that period is $3,333. ...

On the sale, it realized a capital gain of $50,000 and a terminal loss of $60,000 – except that, pursuant to s. 13(21.1), the capital gain became nil and the terminal loss became $10,000, so that pursuant to s. 13(21.1), the deemed proceeds of disposition of the building were $250,000. The Directorate stated: [T]he expression “that would otherwise be the transferor’s proceeds of disposition of the transferred property” used in paragraph 13(21.2)(b) means the proceeds of disposition of the building determined having regard to subsection 13(21.1) … [i.e.] $250,000 … [so that] the vendor would be deemed to own a property with a capital cost of $10,000. ...

. … [T]he term "group … insurance plan”… includes, in particular, accidental death and dismemberment insurance plans. Therefore, if the Insurance Coverage is a group insurance plan, we are of the view that the total amounts paid by the Employer in respect of an employee during a year of Insurance Coverage is to be included in computing the employee's income from an office or employment under paragraph 6(1)(e.1). … [T]hat the Insurance Coverage primarily benefits the Employer … is not relevant for the purposes of paragraph 6(1)(e.1). ...