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. … 1.12 A person who has accepted any funds from the trust in respect of an income interest in the trust, or who has executed a disclaimer in respect of an income interest in the trust in favour of another person, would be considered to have acquired the income interest and therefore would be unable to execute a valid disclaimer. … Meaning of release or surrender 1.13 A release or surrender is either an extinguishment or discharge of a legal right or claim, or a transfer of a legal right or claim to another person. ... The taxpayer must include that amount in income pursuant to subsection 106(2). … 1.14 … Pursuant to paragraph 248(8)(c), a release or surrender by a beneficiary with respect to any property that was property of a deceased individual immediately before death, is not considered to be a disposition of the property by the beneficiary. ... The result will be the same where the taxpayer designates or otherwise agrees which person or persons will benefit by reason of the release or surrender, if the same person or persons would be entitled to benefit in the same way under the trust without the taxpayer's designation or agreement. … ...

S3-F4-C1- General Discussion of Capital Cost Allowance-- summary under Subsection 1100(2.2) Summary Under Tax Topics- Income Tax Regulations- Regulation 1100- Subsection 1100(2.2) Overview 1.41 … [S]ubsection 1100(2.2) … appl[ies] to a transferee only if: the property was depreciable property of the transferor, and was owned continuously by that person, either from November 12, 1981 or from a date that was at least 364 days before the end of the transferee's tax year in which they acquired the property, to the date of acquisition; or the property was previously exempted from the half-year rule because of the application of subsection 1100(2.1) or 1100(2.2) of the Regulations (at the time when the transferor originally acquired the property). Example: Double NAL transfer 1.41 … Scenario A Mr. C is the controlling shareholder of a corporation which has a tax year ending on December 31. ...

For the following particular types of business, the following factors (among others) should be given consideration: development and sale of real or immovable property – the place where the property is situated; merchandise trading – the place where the sales are habitually completed, but other factors, such as the location of the stock, the place of payment or the place of manufacture, are considered relevant in particular situations; transportation or shipping – the place of completion of the contract for carriage, and the places of shipment, transit and receipt; trading in intangible property, or for civil law incorporeal property (for example, stocks and bonds) – the place where the purchase or sale decisions are normally made; money lending – the place where the loan arrangement is in substance completed; personal or movable property rentals – the place where the property available for rental is normally located; real or immovable property rentals – the place where the property is situated; and service – the place where the services are performed. 1.54 Other factors which are also relevant, but generally given less weight than the factors listed above include, but are not limited to: the place where the contract for the sale of property or the provision of services is formed or entered into; the place where payment is received; the place where assets of the business are located; and the intent of the taxpayer to do business in the particular jurisdiction. 1.55 In the case of a single business comprised of more than one of the above-mentioned activities, each activity is considered separately for purposes of determining in which country or countries the business is carried on (this situation should not be confused with the situation in which the taxpayer has separate businesses—see Interpretation Bulletin IT-206R, Separate businesses). ...

Required connection between move and employment/business/education 4.7 To satisfy the condition described in ¶ 4.3(a) or ¶ 4.4 (a), there must be a connection between the individual’s move and one of the following activities: carrying on a business or being employed at a location in Canada or attending an educational institution. ...

Repairs or Running Expense Incidental capital expenditure 1.3 … Where only a minor part of the expenditure is of a capital nature, the CRA's practice is to treat the whole expenditure as a current expense. ... Restoration to original condition 1.5 Where an expenditure made in respect of a property serves only to restore it to its original condition, that fact is one indication that the expenditure is of a current nature. … Technological improvements 1.6 A repair often involves some degree of improvement in technology, materials or workmanship. ... For example, the cost of replacing the rudder or propeller of a ship is typically regarded as a current expense. … Relative value 1.9 … [W]here the engine in an automobile is replaced, it is not only likely that such a replacement will substantially improve or prolong the useful life of the automobile, but the cost is also likely to be substantial in relation to the total value of the property of which the engine forms a part. ...

Required connection between move and employment/business/education 4.7 To satisfy the condition described in ¶ 4.3(a) or ¶ 4.4 (a), there must be a connection between the individual’s move and one of the following activities: carrying on a business or being employed at a location in Canada or attending an educational institution. ...

Example 12 – Personal trainer An employer pays for the cost of a personal trainer for an employee....Some of these services qualify as counselling for the employee’s mental and physical health. ...

Two questions set out by the courts to determine whether such a connection exists for purposes of a retiring allowance are as follows: Question 1 – But for the loss of employment would the amount have been received? and Question 2 – Was the purpose of the payment to compensate a loss of employment? ...

S3-F4-C1- General Discussion of Capital Cost Allowance-- summary under Subsection 13(27) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(27) Capable of producing salable product 1.34 … Example 2 Company B purchased specialized machinery for use in its manufacturing business. ... Application to leased building 1.36 … [S]ubsection 1102(5) of the Regulations requires the cost of a building or other structure to be added to Class 1 (or Class 3) in certain circumstances rather than to Class 13. … [E]ven though a taxpayer may erect a building on leased land, it will still be considered property (other than a building or part thereof) acquired by the taxpayer within the meaning of subsection 13(27) of the Act for the purpose of the available-for-use rules. … ...

S3-F4-C1- General Discussion of Capital Cost Allowance-- summary under Subsection 13(7.5) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(7.5) Access road example 1.48 … Example 4 In order to be able to establish a sports arena at a particular location, a taxpayer builds a road to the arena at a cost of $10 million. ... Exclusion for non-prescribed property 1.49 … If the other person's property is not property described in subsections 1102(14.2) or 1102(14.3) of the Regulations, or if the cost was incurred before March 7, 1996, such cost would generally be a non-deductible, non-depreciable capital outlay that qualifies as an eligible capital expenditure. … ...