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The Directorate responded negatively: [T]he CRA may … reassess the particular taxation year (the taxation year in which a loss was incurred) only to the extent that the reassessment is made before the normal reassessment period for the particular taxation year expires. … The extended reassessment period under subparagraph 152(4)(b)(i) applies only to an assessment or reassessment made under subsection 152(6) of a taxation year for which, for example, a deduction under section 111 in respect of a loss incurred for a subsequent taxation year is claimed. ...

Respecting the subsequent “salary” payments, the Directorate stated: In spite of the fact that contributions of the taxpayer to the pension plans continued to accumulate for the period from Date 4 to Date 5, … the taxpayer and the employer did not have an employment relationship during that period…since [citing Schwartz] she was not required to provide services. … Thus, since… there was no [recommencement] of employment on Date 4… the amounts paid between Date 4 and Date 5 constituted the continued payment of a retiring allowance. ...

. … [T]he capital gain was realized by the Partnership sometime in 2015 and allocated to the Taxpayer at the end of 2015 when the Taxpayer was a resident in Canada. Therefore, pursuant to section 114, the income of the Partnership, including the capital gain realized by the Partnership, must be reported by the Taxpayer on the Taxpayer’s 2015 Canadian income tax return. … [W]hile addressing the importation of losses into Canada, subsection 96(8) does not prevent the recognition of gains in Canada. ...

. … [S]ubsection 104(24) provides a rule of application that alters the ordinary result…only if…an amount has first been determined to have become payable to a beneficiary. As no amount has become payable to a beneficiary pursuant to subsection 104(6), subsection 104(24) has no application. … By analogous rationale, in our view no amount may be included in computing the income for the year of a minor beneficiary under the trust pursuant to subsection 104(13) in this case. ...

. … Thus, to the extent that the annuitant acquired units of the Co-op from the trust governing his RRSP that have a nil FMV, the cost of the units to the annuitant would be deemed to be nil by virtue paragraph 69(1)(a). The excess amount paid by the annuitant to the trust governing the annuitant's RRSP would be treated as a premium, and could result in an over-contribution …. ...

After quoting from Quebec commentary that “[a]s a general rule, the mere delivery of a promissory note does not entail novation of the pre-existing obligation” and the “promissory bill is then considered as a simple means of acknowledging the debt,” CRA stated: [T]he issuance of the note … did not constitute a payment and that there was no novation of the original debt by reason of the issuance of this second note.” After quoting from Québec Cartier, CRA concluded that “the Taxpayer did not pay the increased and annually capitalized interest and did not credit the Vendor with such interest when the [new] note … was issued.” ...

In indicating that there generally was an increase to the ACB of their shares, the Directorate stated: [A] transaction that otherwise increases the capital of a corporation without any consideration being given by the corporation in respect of that increase may result in a contribution of capital …. ... However, paragraph 53(1)(c) will apply only where a contribution of capital to a corporation by a taxpayer holding shares of the capital stock of the corporation results in an increase in the fair market value of the shares of the capital stock held by the taxpayer. … [Here] the capital expenditures incurred by the Shareholders with respect to the Building constitute a contribution of capital to the Corporation. ...

X had not declared an amount in his 2004 return (the "first criterion at issue "). ... X would be subject to a penalty pursuant to subsection 163(1) for his 2004 taxation year …. ...

In this case … the applicable provision- permitting the deduction of amounts repaid in respect of employment insurance benefits- is paragraph 60(n)(iv). Since the taxpayer did not have any amounts to include in the taxpayer’s net income … the taxpayer cannot claim that deduction. ...

The Directorate stated: In general … there is no taxable benefit [where]: the value of the meal or meal allowance is reasonable: in general, an amount up to $17 is considered reasonable; The employee works two or more hours of overtime right before or right after their scheduled hours of work. ... In addition, this condition may be satisfied where a meal or allowance is provided at least three times a week on an occasional basis to meet ad hoc workload requirements such as major repairs or periodic financial reporting. … [A]n allowance that is higher [than $17] may still be reasonable if the cost of meals in a particular location is higher or if there are certain circumstances that justify a higher amount. ...