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. … As to the nature of the income that would have arisen to Corporation at the time of the exercise of the options, we are of the view that this is consideration for the services that were to be rendered by Corporation to Publico. … Consequently, the income generated on the exercise of options granted by Publico would normally be added to the Corporation's business income under subsection 9(1). ...

X, the amount of the benefit … would be added in the computation of the cost of the shares, to Ms. ... X should also include the exercise price of the options …. ...

. … If this condition is not satisfied, the voluntary disclosure can be refused…. ... After noting that a T1134 is required for each foreign affiliate for each post-1995 year, CRA indicated that a s. 162(7) assessment "must be made by the Minister before the expiration of the normal reassessment period" – but noted the exception for carelessness etc. and the potential three-year extension under s. 152(4)(b)(iii). ...

3 October 2014 Internal T.I. 2014-0532051I7- Rent and Part XIII Tax-- summary under Paragraph 212(1)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d) non-commercial arrangement not subject to s. 247 but is subject to Part XIII/property taxes included in rent/no Part XII tax on imputed rent A non-resident individual not carrying on business in Canada ("Owner") leases a Canadian property to a related resident individual ("Tenant") at less than fair market value rent (Scenario 1) – or for no rent at all but with the Tenant being responsible for all expenses including utilities and property taxes (Scenario 2). ... Respecting Scenario 1, the Directorate stated: [T]he fact that the amount of rent…is below… fair market value would… not…impact the amount subject to withholding tax under paragraph 212(1)(d). … [T]he transfer pricing rules in section 247… would generally not be applied to adjust the amount of rent under the circumstances…. ...

. … As a result, the concept of "workplace" is a key element in determining the nature of employee travel. ... The CRA also is of the view that an employee may have more than one workplace. … [T]he regularity and frequency of your visits to the [two] offices are indicators that these two locations could both qualify as “workplaces”. ...

. … Given that it is our view that Weston should not have any effect on Rulings’ policy regarding interest rate derivatives, Rulings’ policy regarding interest rate derivatives would continue to apply and therefore the Bond Locks should be considered to be on income account. … ...

. … [I]f it were determined that such a comparative analysis supported the conclusion that a US LLC must be considered as a partnership for the purpose of application of the Act, we suggest that it would not be appropriate to adopt a classification approach to entities and foreign arrangements which could result in a different classification according to the province or territory of the residence (or permanent establishment) of the taxpayer holding an interest in the entity or the arrangement. … [I]t appears to us, based in particular on the conflict of law rules, that the provincial and territorial laws of property and civil rights in Canada provide for mutual recognition of different types of entities or arrangements established under the respective jurisdictions of the various provinces and territories, thus providing an expanded base for analysis that is uniform across Canada for the purposes of applying the two-step approach. ...

CRA responded: Although … the child appears to be eligible for the disability tax credit …we cannot confirm whether the services that would be offered by a specialized educator (by following the XXXXXXXXXX program or other program) would be tutoring services supplementary to primary education pursuant to paragraph 118.2(2)(1.91) and if a medical practitioner would certify that the child requires such services because of the child’s learning difficulties or mental impairment … based on the information received. ...

The Directorate responded: [T]he penalties under subsections 162(7.01) and 162(7.02) will be calculated from the expiry of the filing deadline … where that information return is made after the extension date determined by the Minister pursuant to subsection 220(3). ... For example, a person who fails to complete 1,000 T4 Slips- Statement of Remuneration Paid and 50 T4SUM Summary of Remuneration Paid within the time prescribed … would be liable to a penalty under subsection 162(7.01) on a total of 1,050 information returns of the same type. ...

A, the Directorate stated: Paragraphs 146(9)(a) and (b) have the effect of adding to the income of an annuitant under an RRSP trust the difference between the FMV of the property acquired by the trust and the consideration given for the property acquired …. Similarly, subsection 146(10) has the effect of adding to the income of an annuitant under an RRSP trust the FMV of any property of the trust used or permitted to be used by the trust as security when the property began to be so used …. ...