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Paragraph 23 of Interpretation Bulletin IT-337R4 explains the limit …. ...

Before finding that it qualified under Class 6(e) as a storage tank, the Directorate indicated that the storage tank did not fall within Class 8(c) as the Directorate did “not believe that the settling tank is a building and that it was acquired for the purpose of "manufacturing or processing" as … decantation is not a physical or chemical change produced by a technique of preparation or handling but rather a change resulting from a natural process.” ...

The CRA's position in this regard is that the condition set out in subparagraph 108(2)(a)(i) is not satisfied where the suspension of redemption rights exceeds one year (see, among others, documents # E 2000-0007513, E 941673, E 933222 and E 913030). ...

Before finding that such incentive payments were includable in the income of such clients under s. 12(1)(x) (absent any election made under s, 12(2.2) respecting the premiums paid) given inter alia that they were received by such clients “in the course of earning income from … property,” namely, acquiring and holding the policies, CRA cited La Capitale (98 DTC 6215) (also regarding an insurance policy) for the proposition that "’property’ in the Act includes practically any type of economic interest” and indicated that “the Policyholder holds property for the purposes of the Act.” ...

Before going on to indicate that such fees were not deductible under s. 60(o) by the shareholder, the Directorate noted that they would have been deductible by the corporation if incurred by the corporation – but were not deductible under s. 9 by the individual since he was not carrying on a business. ...

. … [T]he 2004-2005 T4130 no longer states that reasonable living expenses are limited to a maximum of 15 days. ...

In finding that the grant amounts should be included in capital under s. 181.2(3)(a), the Directorate stated: [T]he net amount of … government grants, which is not a loan or advance, constitutes funds that the government has injected into the taxpayer. ...

The Directorate found that this note disclosure was sufficient to amount to the grants being reflected in the taxpayer’ balance sheet, stating that the “net amount of grants … is therefore identifiable on the balance sheet and, consequently, paragraph 181(3)(b) requires that that amount be used to determine the taxpayer's capital in subsection 181.2(3).” ...

Consequently, the individual would be deemed to have received a dividend pursuant to subsection 84(1) equal to the amount by which the increase in the PUC … of the preferred shares exceeds the amount by which the PUC of the common shares is reduced. ...

On the other hand, if he acquired the mortgage in the course of a business of purchasing debt obligations, the amount of the discount was only to be included in his income after he had fully recovered his purchase price – although it was acceptable to compute a gain as being realized on the receipt of each blended payment. ...