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[W]here … the writer and seller of a particular call option purchases another call option traded in the market that has the same characteristics as the particular option, in order to terminate its obligations [thereunder] … the purchase of the call option constitutes a separate transaction …. ... In the case of the sale of the option by the writer … the cost of the call option sold by the writer is usually nil. ...

15 December 2014 Internal T.I. 2012-0445361I7 F- Remboursement de frais de déménagement-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) criteria for determining “ordinarily resides” under s. 62 (coterminous with “ordinarily resident” under s. 250(3)) Before indicating that the question of whether the reimbursement of expenses of selling a residence at Location 1 in Canada, which had continued to be held by an employee after his relocation to a job abroad at Location 2, could be treated as a taxable benefit if such residence was sold at the time the employee was relocated again to another location and position abroad at Location 3, turned on whether he should be considered to ordinarily reside at Location 2, CRA indicated that the terms "ordinarily reside" and "ordinarily resident" have the same meaning and that “the notion of ‘ordinarily reside’ relates more to everyday life than to the permanent nature of the situation,” and then listed the following indicators as to whether a taxpayer "ordinarily resides" at a particular new location: • the relocation of the taxpayer and the members of his or her household with their belongings, furniture and other items in their household to the new location. • the availability of the former residence, that is to say if it was sold, rented, or if it has been advertised for sale or rent (if the taxpayer is the owner), or if the lease was terminated (if the taxpayer is the lessee). • the chosen residence at the new location accords with the ordinary lifestyle and needs of the taxpayer (for example, if the taxpayer would be able to live in the new residence for an indefinite period or if instead it is a hotel room or a room in a friend’s home). • the transfer of banking services of the taxpayer and the taxpayer's other financial arrangements (including insurance policies) from the old to the new location. • changing the taxpayer’s driver’s licence and registration certificates for non-commercial vehicles (to satisfy the requirements of the new location or to report the new residence address). • a change in health care coverage to the new location. • the transfer of certain services from the old to the new location (e.g., subscriptions to newspapers or magazines, cable, internet, and telephone services). • the transfer of social relationships and other interests, from the old to the new location (such as participation in recreational, social, political or religious activities, and membership in personal or professional organizations). ...

CCRA indicated that s. 110.6(15)(a) would apply, stating: In the context of paragraph 110.6(15)(a) … the term "owned" refers to the person who beneficially owns the property. … Opco owns a life insurance policy on the life of Ms. ... Consequently … the shares of Opco owned by the Trust are deemed to be beneficially owned by Ms. A for the purposes of the Act …. ...

In finding that s. 248(3)(e) would deem the Opco shares to be owned by the spouse for s. 110.6(15)(a) purposes, CCRA stated: In the context of paragraph 110.6(15)(a) … the term "owned" refers to the person who beneficially owns the property. … Opco owns a life insurance policy on the life of Ms. ... Consequently … the shares of Opco owned by the Trust are deemed to be beneficially owned by Ms. A for the purposes of the Act …. ...

CRA responded: [A]n individual owned a home that he inhabited during the four-year period referred to in subparagraph (a)(ii) … if he owned the home he inhabited during that period as his principal place of residence. … [A]n individual does not meet the condition set out in subparagraph (a)(ii) … if the individual owned a home, located in Canada or outside Canada, that he inhabited as his principal place of residence in the four-year period referred to in subparagraph (a)(ii) …. ...

. … Holdco A should pay Part IV tax pursuant to paragraph 186(1)(a) on the dividend it received from Opco on November 30 … since at that time Opco was not connected with Holdco A. … [T[he fact that Opco was connected with Holdco A at any other time during Holdco A's taxation year would be irrelevant. ...

No director, member, or officer shall directly or indirectly receive any profit from his / her position as director, member, or officer. However, it is permitted that a director or officer may be reimbursed for reasonable expenses incurred by him / her in the performance of his / her duties. ... The objects of the corporation must be to only carry on and / or promote SR&ED. ...

11 July 2016 External T.I. 2015-0592681E5 F- RRIF Death of an annuitant-- summary under Refund of Premiums Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(1)- Refund of Premiums consequence of death if named as beneficiary in RRSP contract As part of a background discussion, CRA stated: One of the conditions for an amount to be considered as a refund of premiums as defined in subsection 146(1) requires that the amount be paid to an individual who was, immediately before the annuitant's death: • the Spouse if the annuitant died before the maturity of the RRSP, • a child, or grandchild, of the annuitant, who was financially dependent on the annuitant (collectively, an "Eligible Recipient".) ...

. … [T[o the extent that the expenses incurred are reasonable in the circumstances … the cost of testing for the bacterium could be a deductible expense in computing a taxpayer's income under paragraph 18(1)(a). ...

3 January 1997 External T.I. 9639365- REIMBURSEMENT OF RRSP ADMINISTRATION FEES-- summary under Premium Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(1)- Premium contribution to plan to fund admin fees is a premium The Department briefly stated: [W]here the annuitant makes a payment to his or her RRSP trust as a contribution under the trust to be applied for the purpose of providing the annuitant with a "retirement income" (as defined in subsection 146(1) of the Act) on maturity, the payment is considered a payment of a "premium" as defined in subsection 146(1) … unless it is a payment excluded in the conclusion to that definition. … [A]dministration or trustee fees can also be paid directly by the annuitant outside the trust and that there is no deduction for such payments made after March 5, 1996. ...