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CRA, on a case-by-case basis, has been prohibiting, pursuant to a s. 147.1(5) condition, employers and members from contributing to a money purchase provision of an IPP or to a designated plan if actuarial surplus under the defined benefit provision of the plan is more than the surplus limit – so that any required contributions to the plan’s money purchase provision are permitted only if they are made from the surplus (as permitted by Reg. 8502(k) and s. 147.3(4.1).) ...

. … [U]nder subsection 141.02(8), the following rules apply: the extent to which the consumption or use of the residual input is for the purpose of making taxable supplies for consideration is deemed to be equal to the prescribed percentage for the prescribed class of financial institution the extent to which the consumption or use of the residual input is for purposes other than making taxable supplies for consideration is deemed to be equal to the difference between 100% and the prescribed percentage for the prescribed class of financial institution (that difference being 88% for banks, 90% for insurers and 85% for securities dealers) the extent to which the residual input is acquired by the qualifying institution for the purpose of making taxable supplies for consideration is deemed to be equal to the prescribed percentage for the prescribed class of financial institution the extent to which the residual input is acquired by the qualifying institution for purposes other than making taxable supplies for consideration is deemed to be equal to the difference between 100% and the prescribed percentage for the prescribed class of financial institution (that difference being 88% for banks, 90% for insurers and 85% for securities dealers) for the purpose of determining an ITC in respect of the residual input of the qualifying institution, the description of Element B of the formula in subsection 169(1) is deemed to be equal to the prescribed percentage for the prescribed class of financial institution Required to follow the usual rules for exclusive and excluded inputs A qualifying institution will still generally be required to follow the rules in subsection 141.02(6) in respect of each exclusive input and use a specified method pursuant to subsection 141.02(14) for each excluded input. ...

A taxpayer seeks to avoid the s. 18(19) straddle-transaction rules by acquiring a partnership interest in a partnership that had an accrued loss and gain on the two legs of an FX straddle, with the closing of such acquisition being immediately preceded by the closing out by the partnership of the gain leg so that such gain is allocated to the vending partner pursuant to s. 96(1.01) – and with the loss leg realized after the acquisition and allocated to the taxpayer. ...

Example 8 A municipality provides a transfer payment to an NPO to build a sports facility on municipal land (the primary purpose is to acquire the facility – there is a direct link). ...

Voluntary disposition of Class 14.1 property generally not eligible for replacement property rules. 1.46 … One of the characteristics of a former business property is that the property is real or immovable property or an interest therein. ...

. … Examples Example 1 An individual leases a cottage in the country on a continuous basis over several years. ...

. … Each member of a partnership carries on business as both a principal and an agent of the other members of the partnership. ...