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. … With respect to a building … the use of its square footage is generally an accepted factor that is given significant weight in determining the particular use to which a building is put. ...

In finding that instead there was no Part VI.1 tax payable, the Directorate stated: [T]he common shares … were neither "STPSs" nor "TPSs" …. ... Furthermore, we are of the view that the purchase price per share … did not exceed the FMV of the Corporation's common shares at the time these agreements were entered into or at the time the shares were acquired. ...

Would the payout of the balance in the Reserve (not exceeding 20 days and based on the current salary) on the employee's resignation, dismissal, or retirement qualify as a retiring allowance – or as a death benefit if paid on the employee’s death? ... In a case where an employee dies while still employed … the portion of the amount paid … in respect of the compensation for the maximum twenty (20) days sick leave in the Reserve would be a death benefit since this portion of the allowance would be paid as a result of the employee's death. ...

., 1996 J.Q. no. 5103 … established that support and custody judgments lose all effect when the parents resume living together … [and] that these judgments would not take effect if the parents subsequently separated again. … Since the amounts were paid under a new agreement, which was only a verbal agreement between the parties, that arose following the second separation, the amounts paid by Monsieur do not meet the definition of "support amount" in subsection 56.1(4) …. ...

Finally, although the relative value of labour in relation to the value of the total property suggests that labour is a capital expenditure … this ratio is not necessarily decisive …. [T]he fact that work was not carried out earlier does not change the nature of the work when it is finished, regardless of its total cost. … In Méthé [86 DTC 1364], the TCC stated that the increase in rental income was the most conclusive evidence that the work done by the taxpayer resulted in a nearly new building and not the same original building. … Thus, the increase in gross rental revenues in this case, for the years following the work, will be a factor that will allow us to conclude whether the expenses incurred by the taxpayers were current or capital in nature. ...

. … [A]n amount does not have to be assessed to be an amount referred to in subsection 159(2). Thus, an assessment in respect of the Trust does not have to be issued in order to assess the Legal Representatives pursuant to subsection 159(3). … [I]t is reasonable to consider that … the issuance of the clearance certificate by the CRA does not relieve the Legal Representatives of their personal liability pursuant to subsection 159(3). It is all the more important to consider that, at the time of the request to the CRA for the clearance certificate, the Legal Representatives did not disclose any information relating to the undeclared capital gains. … [P]aragraph 159(3)(b) provides that the Minister may, at any time, assess a legal representative for any amount payable pursuant to that subsection without regard to the normal reassessment period. ...

However, the Directorate preferred the double inclusion alternative: [T]he better view … is that the dividend income and FAPI inclusion are not the same amount … [T]he dividend income is a cash distribution on the shares of S Corporation while the FAPI is a notional allocation of the income of S Corporation deemed to be FAPI on its shares of S Corporation … [so that] the dividend income and FAPI are separate amounts of a different nature … [which] would preclude the application of subsection 248(28). ...

. … Our comments would be the same … if the Corporation had been a large corporation. ...

. … [I]t would seem that the requirements … respecting a BIL appear to be satisfied. ...

Consequently … subsection 146(12) would be applicable [here]. … While it may be appropriate for the issuer to use the services of an independent valuator to determine the FMV, this is not specifically required under the Act. ...