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However, where property, including a building or part of a building, becomes available for use under the two-year rolling-start rule, the half-year rule will not apply in the first year in which the CCA is deductible in respect of the property (see Example 1 as well as ¶ 1.33 and 1.34). ...

The cost of such depreciable property is converted to Canadian dollars in the manner explained in ¶ 1.50. ...

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Subsection 248(36) applies if: a. the deemed fair market value rule applies because the taxpayer acquired the gifted property within the 3-year or 10-year period described in ¶ 1.27(a) and (b); and b. the gifted property had been acquired at any time in that 3-year or 10-year period by any person or partnership that does not deal at arm’s length with the taxpayer. ...

In addition, payments made for the purchase of works of art from a self-employed artist such as under an art bank program are considered to be ordinary business income to the artist …. 1.29 The Canada Council for the Arts distributes annual Public Lending Rights (PLR) payments to Canadian authors through the PLR program as a form of discretionary cultural support to eligible individual creators of literary and scholarly works that are found in the public library collections. ...

. … 1.29 [I]t is possible for each of two unrelated persons to be regarded, for the purposes of subsection 251(2), as having control of the same corporation at the same time. ...

. … 1.13 Usually the frequency and systematic nature of an activity would be indicative of a business. ... More recently, the Tax Court of Canada went on to state that: … Gambling- even regular, frequent and systematic gambling- is something that by its nature is not generally regarded as a commercial activity except under very exceptional circumstances. ...

Further, subsection 84(3) will not otherwise apply to deem a shareholder of a predecessor corporation to have received a dividend where the shareholder exercises its statutory dissent rights in respect of the amalgamation and receives payment for its shares from the new corporation.... 1.6 Regarding the condition described in ¶1.1(c), the CRA will not ordinarily apply subsection 245(2) to an amalgamation that is undertaken to squeeze out minority shareholders whereby the redeemable preferred shares received by the minority shareholders are redeemed shortly after the amalgamation (see paragraph 28 of Information Circular 88-2, General Anti-Avoidance Rule – Section 245 of the Income Tax Act). 1.35 Where one predecessor corporation has a leasehold interest in a property owned by a second predecessor corporation, the application of section 87 to the amalgamation will only be accepted where subsection 13(5.1) is applied concurrently as if the new corporation is the same corporation as, and a continuation of, the first mentioned predecessor corporation.... ...

Consequently, subsection 87(3.1) permits the new corporation to elect not to have the provisions of subsection 87(3) apply where both of the following conditions are satisfied: (a) all of the issued shares of each class of shares (other than a class of shares all of the issued shares of which were cancelled on the amalgamation) of each predecessor corporation are converted into a separate class of shares of the new corporation; and (b) after the amalgamation, the number of shareholders of each class, their proportionate ownership of each class, the number of issued shares of each class, the issued capital of each class for corporate law purposes and the terms and conditions of each class of shares of the new corporation are identical to those that existed for the particular class of shares of the predecessor corporation which were converted into that separate class of shares of the new corporation. 1.89 If the conditions in … (a) and (b) are satisfied and the new corporation elects in its return of income for its first tax year to have subsection 87(3.1) apply, each class of shares of the new corporation issued on the amalgamation will be deemed to be the same class as, and a continuation of, each class of shares of the predecessor corporation converted on the amalgamation for the purposes of computing their paid-up capital. ...

. … These conditions are: (a) the predecessor was not dealing at arm's length (otherwise than because of a right referred to in paragraph 251(5)(b)) with the new corporation immediately before the amalgamation (paragraph 1100(2.2)(e)); and (b) the property was depreciable property of the predecessor corporation and either: (i) was owned continuously by the predecessor corporation from a day that was at least 364 days before the end of the new corporation's first tax year to the date of the amalgamation (paragraph 1100(2.2)(f)), or (ii) subsection 1100(2.1) or 1100(2.2) of the Regulations applied to the predecessor corporation on its original acquisition of the property (paragraph 1100(2.2)(g)). 1.32 With respect to the condition described in ¶1.31(a), subsection 251(3.1) deems the new corporation formed on an amalgamation to be related to (and, therefore, not deal at arm's length with) a predecessor corporation where the two corporations would have been related immediately before the amalgamation if the new corporation had been in existence at that time with the same shareholders that it had after the amalgamation. ...