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CCRA responded: If the GST/HST collected and remitted is in respect of a benefit included in an employee's income pursuant to paragraph 6(1)(a), (e), (k) or (l) … the corporation may deduct it in computing its income from a business or property. … [I]f [instead] the GST/HST collected and remitted is in respect of a benefit included in a shareholder's income under subsection 15(1) … the corporation cannot deduct it in computing its income from a business or property since it would not be considered to have been incurred for the purpose of earning its income from the business or property. ...

. … As a result, the TFSA trust would be considered to have borrowed money”. … However, where an overdraft is created in respect of fees charged to the TFSA but which remain unpaid… [this] would not constitute borrowing of money or other property for the purposes of paragraph 146.2(2)(f). … Turning to the cashless exercise of warrants, CRA stated: [T]he broker advanced the funds to the TFSA trust necessary to exercise the warrants in question. ...

The Directorate stated: Since the wording of subsection 105(1) refers simply to a "taxpayer", we are of the opinion that this provision may apply to a taxpayer who has received a benefit from a trust of which the taxpayer is neither a beneficiary nor a trustee, even if the taxpayer is not related, directly or indirectly, to a beneficiary or trustee of the trust …. Subsection 105(1) can therefore apply to Canco, notwithstanding Canco not being a beneficiary …. ...

Before [any] corresponding adjustment is made … the conditions of paragraph IV(6) should still be met since Parentco is considered to have derived an amount (that is not disregarded) through US Sisterco LLC. More specifically … from a US tax perspective, Parentco, will have a reduced cost of inventory that is derived through the purchases of Sisterco LLC from Canco. ... Either way … that amount [is not] “disregarded” for US tax purposes …. ...

. … [A]lthough the Policy is property acquired for the purpose of earning income from property … these premiums are not deductible in computing the taxpayer's income because of the special rules applicable to life insurance policies. ...

. … [I]n determining whether [NR1’s] partnership interest is excluded property … any assets held by the partnership on which income was or would be recharacterized as active would qualify as excluded property under paragraph (c). ... The Directorate went on to find that if the partnership interest disposition date was 6, the cash held at that time did not qualify as an active business asset (noting that it “being used in a continuation of the active business activities undertaken by FORP, as it had never carried on an active business”); and that on the dissolution date no property was held – so that, either way, para. ...

This is in contrast to a subsection 66.1(2) deduction … [which] cannot result in the preservation (or creation or increase) of a non-capital loss. … [E]ven though deductions under subsection 66.7(3) (as well as under subsections 66.7(4) and (5)) might effectively preserve all or part of a current year loss as discussed above, they cannot, in and of themselves, create or increase a taxpayer’s non-capital loss. ...

After noting that “the weekly blood tests in this case would likely be considered an activity that would be included in the time spent administering therapy” since the “weekly blood tests were required to ensure that the proper Phe level was being maintained,” the Directorate stated: It is … a question of fact whether the determination of a specific activity, for example a weekly blood test, can be included in the time spent administering therapy as described in paragraph 118.1(1)(a.1) of the Act. … What would be considered essential to one person’s impairment may not be considered essential to another. ...

Accordingly … “three months” generally means the aggregation of the number of days in three months. ... Thus, preparation time generally would not be counted towards the three month testing period. … Regarding standby time, i.e., “generally a temporary pause from operation that could be caused, for example, by severe weather, or shortage of labour,” it stated: Such temporary interruption should not change the status that the installation or drilling rig or ship in question is being utilized in the business. ...

After finding that there was no exemption for the diplomat in Art. 34 of the Vienna Convention on Diplomatic Relations from the s. 162(7) penalty as the property " was not held on behalf of the sending State as part of the mission," nor was there any exemption for the child, CRA stated that "you may wish to consider exercising discretion in assessing the penalty given that….there was a loss on the property. ...