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Therefore, the applicable penalty provided by paragraph 162(7.01)(b) … is $15, multiplied by the number of days, not exceeding 100, during which the failure continued. ...

"... the Department has decided that 'portfolio investments' as used in subsection 206(1) of the Act takes on its common dictionary meaning of 'all the securities held by an investor'. ...

. … The reference to paragraph 110(1)(d) in the adjustments to the taxpayer's world income in subclause 126(1)(b)(ii)(A)(III) also supports our conclusion. ...

It is therefore our view that tips should be excluded from "labour costs" …. ...

Consequently, the fact that no provincial tax was paid by the Trust in respect of the dividend received … cannot, in our view, trigger the application of the GAAR. ...

Thus, the "Payroll Taxes" and "Social Security Taxes" in this situation must be considered "non-business income taxes" …. ...

The Directorate stated: [U]nder the terms of subsection 231.5(1) … where, pursuant to sections 231.1 and 231.2, electronic records (such electronic records being "records" within the meaning of the definition of "record" in section 231 and the definition of "record" in subsection 248(1)) are being audited or reviewed or produced, the person who is doing the auditing or reviewing, or to whom the production is made, or any CCRA official, may make or cause to be made electronic copies of them. ...

The Directorate, in noting that “[i]t is possible that the person paying salary or wages is not the employer,” repeated the statement in Mollenhauer “that subsection 153(1) … does not speak of whether persons doing the paying are employers or not,” and went on to find that the individuals likely were employees of Cco, so that the charges from Bco for their salaries likely could be included in the “cost of labour” of Cco under Reg. 5202. ...

Consequently, the functions or services performed by the subcontractors do not fall within the definition of "cost of labour" …. ...

15 April 2004 Internal T.I. 2004-0062451I7 F- Résidence principale-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence- Paragraph (c) no need to file form for principal residence portion of disposed-of property if it was fully exempted A taxpayer disposed of land in excess of ½ a hectare, did not file a Form 2091, did not report any capital gain, and on audit was unable to demonstrate that the excess land was necessary for the use and enjoyment of the residence, so that there was a capital gain on the disposition of such excess land. ...