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As for the missions covered for the purposes of subclause 110(1)(f)(v)(v)(A)(II), they are provided for in [Reg.] 7500 …. ... Furthermore …, it would appear that the … operations in which the taxpayer participated are missions referred to for the purposes of subclause 110(1)(f)(v)(A)(A)(II). … [T]he question of whether someone is a member of the Canadian Forces must be resolved in light of the relevant provisions of the National Defence Act. ...

After finding that he was not able to deduct the legal fees incurred by him in negotiations with the tax authorities, the Directorate went on to state: … E9930565, F9809347 and E9608715 … discussed the tax treatment of the debt paid by directors in discharge of their joint and several liability with a corporation … [and concluded] that the debt arising to the directors from their obligation had not been acquired with a view to earning income from a business or property. ...

Before finding that these premiums were not deductible in computing his income from a business, CRA stated: Where an insurance broker, who is self-employed, receives a commission from the sale of a life insurance policy owned by him …CRA … is generally of the opinion that this income does not have to be included in the calculation of the broker's business income as long as the broker is required to pay the premiums relating to the policy. ... Notwithstanding our position stated above, we are of the view that … the commission received or receivable could be considered taxable … where the amount of the commission is substantial. … Thus, because of the amounts of commissions received, it is likely that they will have to be included in the broker's income for the year in which they are received. ...

16 December 2008 Internal T.I. 2008-0300361I7 F- Déductibilité de l'impôt minimum sur les sociétés-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose Ontario CMT is non-deductible In finding that the Ontario corporate minimum tax ("CMT") provided for in ss. 57.1 to 57.12 of the Corporations Tax Act was not deductible in computing income, the Directorate first noted that the “CMT is therefore a calculation of tax based on a corporation's income, with adjustments, appearing in its financial statements,” and after quoting the statement in Roenisch, 1 DTC 199, that “such payment of taxes … made to the province … is not so made to earn the income, it is paid because there is an income showing gain and profit,” the Directorate stated: Since the CMT is a tax effectively calculated on income, it is therefore not deductible by virtue of paragraph 18(1)(a). ...

In finding that the Corporation was not entitled to a deduction in 2001 for the CADD amounts pursuant to s. 20(1)(vv), and before going on to find that s. 18(1)(e) denied a s. 9 deduction, the Directorate stated: Paragraph 20(1)(vv) … allows for the deduction of such duties as long as they are paid. … In the current context, [“paid’] … means "to discharge a debt". ... Consequently, we are of the view that the provisions of paragraph 20(1)(vv) do not apply …. ...

The Directorate stated that the presumption s. 7(3)(b): prevents Pubco from deducting in computing its income an amount of expense calculated on the exercise of an Option and the issue of a share that results in a taxable benefit under paragraph 7(1)(a) … [so that] the "stock-based compensation expense" … is not deductible by Pubco in computing its income for income tax purposes …. ...

Therefore …the employee was required to include in her employment income … under subsections 6(3) and 5(1), all amounts [so] received …. …[I]f the employee reimburses in 2010 the balance owing … in respect of the deferred salary leave plan, she could take the deduction under paragraph 8(1)(n) in computing her income for 2010. … [S]uch a deduction would be limited to the amount advanced and paid during the period of deferred salary leave, which had already been included in her income. ...

16 April 2024 Internal T.I. 2023-0998991I7 F- Qualification fiscale de certaines sommes-- summary under Paragraph 56(1)(n) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(n) amount per week of training in short-term program leading to a skills training certificate was a bursary/ amount paid upon graduation was a bursary or a prize Regarding the tax treatment of amounts paid as part of a Construction Sector Training Initiative, namely (a) $750 per week of training, paid every two weeks to an individual who registered between October 30 and December 15, 2023 in a short-term study program leading to a skills training certificate; and a "bourse de perseverance [persistence bursary]" in the amount of $9,000 to $15,000 paid to an individual upon graduation if certain eligibility criteria were satisfied, the Directorate stated: [T]he … $750 per week of training that will be paid to an individual enrolled in a program of study leading to a skills training certificate … qualifies as a bursary since it is paid so that the individual can continue the individual’s studies. … [T]he "bourse de persévérance" … qualifies as a bursary if it is paid for the pursuit of studies, whereas it qualifies as a prize for achievement in a field of endeavour ordinarily carried on if it is paid in recognition of obtaining a diploma. ...

A solely on the basis of that provision, as determined in Massicotte …. ... A would have received a benefit … under subsection 15(1). Thus … although the residence is owned by the Partnership, Holdco, as a partner with a 98% interest in the Partnership, may exercise sufficient influence over the Partnership to be able to confer a benefit indirectly on Mr. ...

CRA responded: [W]here salary and wages are paid to an eligible employee and returned to the eligible employer with a corresponding increase or credit to a due to shareholder loan account or other shareholder loan account, we consider such salary or wages would not be eligible remuneration … pursuant to paragraph (c) …. Similarly, salary and wages paid but returned to the corporation by the shareholder/employee as a capital contribution or as an amount re-loaned to the corporation would not be considered eligible remuneration …. ...