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. … Where a debt obligation is transferred between scheduled interest payment dates … [p]aragraph 20(14)(a) will have the effect of adding to the transferor's income, for the year of the transfer, any interest accrued at the time of the disposition that was not included in computing the transferor's income and that is not payable until after the time of the transfer. ...

Where a third party reimburses the RRSP trust's expenses on the sale of the units, or off-sets the expense by transferring in new units of an equivalent value to the redemption fee, this would not be considered a contribution to the trust by the annuitant or a spouse …. Thus, the payment would not be considered a "premium" as defined in paragraph 146(1)(f) … and would not be deductible pursuant to subsection 146(5) of the Act. ...

The Excise and GST/HST Rulings Directorate queried the view in 2014-0530691E5, respecting language, similar to that quoted above, appearing in ITA s. 8(1)(i)(i), that: a professional status would generally have to be acknowledged in the statute itself to satisfy the “recognized by statute” condition in subparagraph 8(1)(i)(i) …. After stating that Montgomery: clarified that the phrase “recognized by statute” should be afforded a broad interpretation, and that “recognized by statute” does not necessarily mean that a professional status was incorporated, created, or regulated by a particular statute and noting that 2014-0530691E5 was somewhat inconsistent with 2012-0444181M4, the Income Tax Rulings Directorate concluded: [W]e would agree with your views that for purposes of the meaning of the phrase “professional status recognized by statute” … applying a textual, contextual and purposive analysis, a “professional status” can be “recognized by a statute” for purposes of subparagraph 8(1)(i)(i) … even if it is only recognized in the supporting regulations of an act. However … where a “professional status” is only acknowledged in an organization’s bylaws, the “professional status” would not likely be considered “recognized by statute” …. ...

. … [T]he fact that a government agency guarantees other aspects of the loan should not in itself prevent the taxpayer from deducting life insurance premiums that otherwise satisfy the other conditions for the application of paragraph 20(1)(e.2). … [P]remiums payable by virtue of a disability insurance policy required by the financial institution … are not covered by paragraph 20(1)(e.2) or any other provision of the Act and are not deductible in computing the taxpayer's business or property income. ...

CCRA noted that it was a question of fact whether her borrowing was for the purpose of earning income from property, that “it is the net loss or income determined under the Act that is … attributed” pursuant to s. 74.1(1), so that “the interest expense paid by Ms. A … will be taken into account in determining the loss or income to be attributed to her spouse … pursuant to subsection 74.1(1),” and that s. 245(1) might be determined to apply. ...

CCRA responded: If the GST/HST collected and remitted is in respect of a benefit included in an employee's income pursuant to paragraph 6(1)(a), (e), (k) or (l) … the corporation may deduct it in computing its income from a business or property. … [I]f [instead] the GST/HST collected and remitted is in respect of a benefit included in a shareholder's income under subsection 15(1) … the corporation cannot deduct it in computing its income from a business or property since it would not be considered to have been incurred for the purpose of earning its income from the business or property. ...

. … This position is based on the definition of "proceeds of disposition" in section 54 … which specifically provides that the proceeds of disposition of a property include the sale price of property that has been sold, and on the relevant jurisprudence …. ...

EXPLOITEE ACTIVEMENT-- summary under Paragraph 79.1(6)(b) Summary Under Tax Topics- Income Tax Act- Section 79.1- Subsection 79.1(6)- Paragraph 79.1(6)(b) meaning of expenses incurred to protect creditor's rights What constitutes an “outlay or expense made or incurred … by the creditor at or before that time [of the seizure] to protect the creditor’s … right, in the particular property” for the purposes of s. 79.1(6)(b). ...

New structure: Common Shareholders of Newco (following the entering into of a shareholders' agreement many of whose terms are similar to the former Partnership Agreement) will have the option of providing their services personally or by using a "New Contracting Corporation" which is owned by, and is the employer of, him or her – except that preference shares may be held by family members – so that each New Contracting Corporation will provide services for agreed fees, will be responsible for specified expenses such as professional membership fees, insurance premiums, education expenses, travel expenses and entertainment expenses (with Newco to provide each New Contracting Corporation with certain supplies, facilities and equipment but with their fair market value to be borne by the New Contracting Corporation), and with the New Contracting Corporation free to compete with Newco. ...

. … Respecting your last question, the described acquisition of the shares … of Opco by A, B and C and would establish respective interests of 31%, 14%, 16% and 39%. ...