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. … That being so, para. 2.59 of the Folio [provides] … that there is no deemed disposition [if]: a) the income-producing use is ancillary to the main use of the property as a residence; b) there is no structural change to the property; and c) no CCA is claimed on the property. In your situation, it is not clear that … the income-producing use is ancillary to the main use of the property as a residence. ...

The Directorate stated: Opco must deduct in computing its safe income on hand attributable to the shares held by Holdco all amounts paid by it during the relevant calculation period as premiums under the Policy …. However, since the Policy has a cash surrender value … the portion of the premiums paid that did not reduce the gain inherent in the shares of the capital stock of Opco held by Holdco, that was not deducted in computing the net income of Opco pursuant to the Act, and that contributed to the increase in the cash surrender value of the Policy, should not be deducted in computing the safe income on hand of Opco attributable to the shares held by Holdco in the relevant period. Based on the information you have provided to us, this amount is equal to … the ACB of the Policy. ...

-resident beneficiary of her deceased mother’s individual pension plan (IPP) received monthly benefits thereunder that were eligible for the 15% Treaty-reduced rate under the Treaty – but thereafter the IPP was wound up by virtue of having reached the end of a 10-year guarantee period. ... CRA went on to gratuitously state: [A]ny additional payment that an IPP may be required to make in a particular year to comply with the IPP minimum amount rules in [Reg.] 8503(26) … is not considered to be a periodic pension payment. … Similarly, a commutation payment made to a member or a beneficiary of a member in full or partial satisfaction of their entitlement to benefits under a defined benefit RPP is not a periodic pension payment. ...

CRA further announced in 2020-0846751E5: In these extraordinary [COVID] circumstances, a HCSA that qualifies as a PHSP and which has unused credits expiring between March 15 and December 31, 2020, could temporarily permit the carry forward of those unused credits for a … period of up to six months [which] would generally … not, in and of itself, disqualify the HCSA from being a PHSP. [emphasis added] In generally extending these periods, CRA now stated: In light of the severity of the second wave of the COVID-19 pandemic, the CRA will allow a HCSA that qualifies as a PHSP and which has unused credits expiring between March 15, 2020 and March 16, 2021, to temporarily carry forward those unused credits for a period of up to 12 months. … However, since a HCSA must involve a reasonable element of risk to qualify as a PHSP, it is our view that any further extension of the temporary carry-forward period beyond 12 months, would likely disqualify the HCSA from being a PHSP. ...

2 June 2010 External T.I. 2009-0343381E5 F- Frais de préposé aux soins-- summary under Paragraph 118.2(2)(b) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(b) behavioural and cognitive therapy of autistic child 35 hour per week likely was not “care” A mother of an autistic child, who qualifies for the credit for mental impairment in subsection 118.3(1), hired an applied behaviour analysis therapist to intellectually stimulate her child, and who cares for the child 35 hours a week, using an individual analysis teaching methodology to stimulate cognitive skills on a daily basis and increase the child’s autonomy – as well as applying behavioural strategies. CRA stated: [Such] expenses … cannot be characterized as for "care" within the meaning of paragraph 118.2(2)(b) since what is involved is more a matter of there being a learning endeavour in order to meet the personal needs of the person with an impairment than of assisting that person in daily activities that the person cannot perform on the person’s own because of the person’s impairment. However … if the therapist's expenses satisfy all the conditions of application of one of paragraphs 118.2(2)(a), (e), (I.9) or (I.91), the therapist's fees could then give rise to an entitlement to the tax credit …. ...

5 May 2021 IFA Roundtable Q. 4, 2021-0887601C6- 2021 IFA Q4- section 247 Post Cameco-- summary under Paragraph 247(2)(a) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2)- Paragraph 247(2)(a) Cameco may limit the use of s. 247(2)(d) recharacterization – and acknowledges that s. 247(2)(c) must take into account a relationship’s circumstances Regarding the CRA response to the TCC and FCA decisions in Cameco, CRA stated “that these decisions may limit situations where the re-characterization provision in paragraphs 247(2)(b) and (d) could be applied … [h]owever, the CRA will continue to consider the application of the re-characterization provision where appropriate.” CRA further stated: The CRA will continue to administer … 247(2)(a) and (c) in a manner consistent with the guidance … [in] General Electric [para. 54]: “…The task in any given case is to ascertain the price that would have been paid in the same circumstances if the parties had been dealing at arm’s length. ...

The CRA summary stated: " Generally such activities will not be a source of income. " ...

. … [T]he concept of “minimal remuneration” should not be applied restrictively. … [T]he factors to be considered include whether the firefighter was subject to former subparagraph 6(1)(b)(viii), the nature of the duties performed, whether the firefighter can accept or refuse to report for duty based on availability, the total annual remuneration paid to the firefighter, and the maximum exemption amount provided for in proposed subsection 81(4). ...

. … [A] housing unit in a semi-commercial building would also be a "qualifying home" …. ... The term "principal place of residence" is not defined …. ...

. … the Company shall make a payment in cash, … to or for the benefit of the Beneficiary of the Participant. ...