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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. ...

19 October 2005 Internal T.I. 2005-0151211I7- Financing expenses-- summary under Paragraph 20(1)(e.1) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e.1) indirect use test inapplicable to s. 20(1)(e) or (e.1), and “relate solely to … year” test not satisfied by lump sum issue fee reimbursement to parent A Co, a public company, issued interest-bearing debentures to arm's length parties, and on-lent the borrowed money to its "great-grandchild" subsidiary (D Co) at the same interest rate. ...

Deloitte & Touche Inc., [2007] 2 C.T.C. 253, 30 C.B.R. (5th) 81, (Sask. ...

In this context, the use of the terms "action de remplacement " and "share for which the affiliate share was substituted" in the French and English versions of paragraph 93(2.01)(a) refer to the concept governed by paragraph 248(5) in respect of property that is shares. ...

. … There is a logical connection between the income from ULC and the U.S. taxes paid by Taxpayer because if Taxpayer did not own such shares, no U.S. taxes would have been paid [citing Smidth]. ...

In this context, the use of the terms "action de remplacement " and "share for which the affiliate share was substituted" in the French and English versions of paragraph 93(2.01)(a) refer to the concept governed by paragraph 248(5) in respect of property that is shares. ...

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. … [I]f the employee did not intend at the time the salary deferral arrangement was created to return to work after the leave for a period at least equal to the duration of the leave, the deferred amounts must be included in the employee's income in the taxation year in which they were deferred. … In addition, if the employee decides during the course of the arrangement to retire at the end of the leave and does not return to work as initially provided for in the arrangement, the deferred amounts will be taxed in the year in which it is known that the above-described condition will not be satisfied. ... The Directorate responded: [I]f, prior to the leave, an employee was working full-time, then upon the employee’s return to work, the employee must once again work full-time within the employer's business …. If the employee was working part-time before the leave, the employee may return to work part-time or on a busier schedule …. ...

. … In addition, since employees reside in Ontario, the compensation paid must not exceed the compensation payable under Ontario's Workplace Safety and Insurance Act. If the employer guarantees the full amount of wages or a percentage that is greater than the percentage payable under Ontario's workers' compensation legislation, the amounts received by the employee in excess of the compensation payable under the provincial legislation are fully taxable. … [B]enefits received by an employee pursuant to an employer's obligation under the Code are considered to be received under a federal workers' compensation statute for the purposes of paragraph 56(1)(v) and subparagraph 110(1)(f)(ii). … Compensation received under a workers' compensation act of Canada or of a province in respect of injury, disability or death must be included in computing the employee's income pursuant to paragraph 56(1)(v). ... No withholding under subsection 153(1) is required …. [T]he use of the administrative services of an intermediary does not change the above tax consequences. ...