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However, paragraph 6(1)(l) … allows a benefit relating to the operation of an automobile to be included in the income of an employee of a member of a partnership since the employee enjoys the benefit because of the employee’s employment. ...

Consequently, we are of the view that paragraph 67.1(2)(c) would apply in those cases …. ...

In rejecting the retroactive application of this provision, the Directorate stated: Although an order dated after April 1997 may deem or stipulate that child support amounts payable or receivable after that date will be subject to the pre-May 1997 support rules … we are of the view that such tax consequences do not arise because an order has so stipulated. ...

16 August 2001 Internal T.I. 2001-0079317 F- RESIDENCE PRINCIPALE DEMI-HECTARE-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence- Paragraph (e) exemption could be claimed only for one lot/ CCRA does not normally challenge contribution to enjoyment of residence of under ½ hectare if no commercial use The taxpayer acquired a lot on which he constructed a residence and also used in part for business purposes and also acquired an adjoining lot on which he erected buildings used for business purposes. ...

Furthermore … the damages do not represent employment income. The amounts received for material and moral damages would therefore not be taxable. ...

Furthermore, “suretyship is generally distinguished from insurance on the basis that the latter compensates for a loss that may arise from a future and uncertain event, whereas suretyship generally covers an existing obligation to a creditor” – so that the partnership was not providing insurance. ...

This has the effect of applying the old rules on support, which means that Monsieur could deduct the amounts paid and Madame would be taxed on the amounts received under that judgment …. ...

12 March 2002 Internal T.I. 2001-0094067 F- DEDOMMAGEMENT- TITRE DE PROPRIETE-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) damages received for separated spouse’s unlawful use of taxpayer’s property were tax-free receipts Monsieur received damages from his separated common-law spouse (Madame) to compensate him for her use of his ½ co-ownership interest in a property as if she were the full owner. ...

12 March 2002 Internal T.I. 2001-0094067 F- DEDOMMAGEMENT- TITRE DE PROPRIETE-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees legal fees incurred in ownership dispute were capital expenditures After his discovery that his separated common-law spouse (Madame) was selling a property in which he had a ½ co-ownership interest, Monsieurs obtained a judgment requiring recognition through a deed of his co-ownership interest and a second judgment requiring her to account for her management of the property in the interim, which resulted in Monsieur receiving a lump-sum damages payment. ...

CCRA indicated that if this return of premium on death clause was ancillary to critical illness insurance, the insurance policy would be a sickness or accident insurance policy – in which case, there would be no taxable benefit under s. 6(1)(a) if it were a group sickness or accident insurance plan. ...