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It was “Rulings’ view that allowing subsection 220(2.1) to waive a taxpayer’s requirement to file an election not listed in Regulation 600 would negate the specific intention of Parliament in limiting late elections to only those that are prescribed in [Reg.] 600” – and, in any event, the CIF provision was not a provision of the Act itself, as required by s. 220(2.1). ...

. … Given the fact that a non-resident that receives a letter containing proposed assessed amounts would almost certainly make a valid paragraph 94(3)(f) election before an audit assessment is actually issued, it appears unlikely that such a non-resident would ever be prevented from making a valid election. ...

. … [I]n... Kaiser... 91 DTC 1057...the taxpayer tried [unsuccessfully] to convince the Tax Court that foreign taxes paid on employment income were deductible under subsection 20(12).... ...

. …. If, in the case described, there in fact is an allocation of capital gains of the SEC to its partners, we believe it would be difficult to maintain that they do not retain their character in the hands of the latter, including the Limited Partner.... ...

. … Justice L'Heureux-Dubé seemed to suggest that Mara Properties stands for the proposition that subsection 88(1) deems the parent to have received property of the same character from its subsidiary upon the subsidiary's wind-up. ...

. … If the total of all the decreases exceeds the total of all the increases to the UCC of a class as of the end of a taxation year, subsection 13(1) provides that this excess shall be included in computing the taxpayer's income for the year. ...

(a)(i) of the "earnings" definition) – without duplication of the adjustments in 1 and 2. ...

" This could be the case given that the payment of the dividends may have fully accessed any available exempt surplus of CCo, whereas if there instead had been a sale of CCo shares to NR1 at a gain followed by a s. 93(1) election, the amount of exempt surplus which was accessed under the operation of Regs. 5902(1) and 5901 could be more limited – which would result in pre-acquisition surplus dividends grinding basis under s. 92(2) which, in turn, would result in a taxable capital gain which was foreign accrual property income. ...

. … If it is instead established on the facts that the taxpayer did not ordinarily reside at Location 2 before ordinarily residing at Location 3…[e]xpenses related to the sale of the residence at Location 1 would be considered expenses of the move from Location 1 to Location 3…. ...

…[T]he CRA should not accept the adjustment request … as it would result in changes to the tax assessment for Year 1, which is a statute-barred year. ...