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The Directorate stated: Burnco states that "an expense within the meaning of paragraph 18(1)(a) … is an obligation to pay a sum of money. ...

8 November 1995 Internal T.I. 9525077- NON-COMPETITION PAYMENTS-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property In considering the treatment of payments received by a shareholder pursuant to a non-competition agreement, the Department stated: "Property is broadly defined in subsection 248(1) of the Act to include, '... a right of any kind whatever...'. ...

Consequently … the amount that would be included in computing X's income pursuant to subsection 15(1) or 246(1) would be added in computing X's cost of the property acquired from Opco. ...

28 April 2004 Internal T.I. 2004-0067561I7 F- Impôt de la partie I.3-- summary under Paragraph 87(2)(a) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(a) no IT-474, para. 10 relief for acceleration of Part I.3 tax In connection with the taxpayer’s reference to the statement in IT-474, para. 10 that “[w]here the provisions of paragraph 87(2)(a) produce unintended consequences which are unfavourable to the taxpayer, the Corporate Rulings Directorate … is prepared on a case by case basis to consider whether relief is appropriate,” the Directorate indicated that no such relief was available respecting an acceleration of Part I.3 tax resulting from an amalgamation. ...

The Directorate noted: For the purposes of the definition of "commencement day", the child support amount is considered to have been changed if the amount of child support paid is changed … regardless of the number of children covered by that support. ...

The Directorate stated: [T]he tax payable under subsection (e) of section 1159.2 … is a payroll tax that may be deducted in computing the taxpayer's income. ...

25 June 2002 Internal T.I. 2002-0130177 F- DEBENTURE CONVERTIBLE-- summary under Paragraph 20(1)(f) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(f) amount paid by corporation on conversion of convertible debentures was the stated capital of the issued shares, being the debentures’ face amount, so that no s. 20(1)(f) deduction The issuer, whose convertible debentures were converted, sought to take a ¾ deduction under s. 20(1)(f) based on the excess of the market value of the shares into which the debentures were converted over the face amount of the debentures. ...

16 August 2002 Internal T.I. 2002-0156577 F- ASSURANCE- INVALIDITE- PARITE-- summary under Paragraph 6(1)(f) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) previous contributions could be deducted from subsequent equalization adjustment received In finding that a taxpayer could deduct contributions made to a disability insurance plan between 1990 and 2001 from an equalization adjustment received in 2001 that related to disability insurance benefits received by the taxpayer in 1988, the Directorate stated: [T]he wording of the Act does not restrict the deductibility of contributions made between 1990 and 2001, even though they were made after the first benefits were paid in 1988 …. ...

Therefore, the pension benefit will be deemed to be income of the beneficiary for the year from a property that is an interest in the Estate and not from any other source pursuant to subsection 108(5) ….. ...

However, in its immediately preceding taxation year, the definition of "investment business" in subsection 95(1) … did not apply to FA2 with reference to Canco because that definition only applies with reference to a "a foreign affiliate of a taxpayer". ... After noting that the wording of s. 138(11.91)(e) "does not mesh well with the definition of ECE" in s. 14(5) given that such definition requires an "outlay or expense made or incurred … as a result of a transaction," CRA nonetheless concluded that the wording of s. 138(11.91)(e) of the Act was "sufficient to cause FA2 to be considered to have made an ECE at the relevant time. ...