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26 February 2014 External T.I. 2013-0510921E5 F- Remboursement de frais médicaux à un employé-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose no need to demonstrate income production In providing a general response to the question as to whether in computing an employer could deduct, in computing its business income, amounts paid to an employee as a reimbursement for medical expenses incurred by the employee prior to implementing a health service plan, CRA stated (TaxInterpretations translation): Under the expression "... for the purpose of gaining or producing... ...

2012 Ruling 2012-0452291R3- XXXXXXXXXX- ATR-- summary under Share Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Share MRPS were shares A Canadian public company (Pubco) (acting through a branch in Country 1 – assumed here to be Luxembourg) will subscribe with cash for common shares and/or mandatorily redeemable preferred shares ("MRPS") of Finco. ...

When asked " How will the CRA monitor to determine whether a testamentary trust is beneficiary of an inter vivos trust? ...

XXIX A(3)) – so that no such benefits would be available here as the earnings of the LLC are derived by individuals. ...

CRA responded: [P]aragraph 402(4)(c) … would apply to calculate the distribution of gross revenues for a year attributable to a permanent establishment in a province without regard to the fact that the sale was negotiated by a person assigned to the permanent establishment located, for example, in Province B. ...

. … …This is consistent with the June 6, 2012 comfort letter from the Department of Finance…[which] confirmed that the amendment was not intended to accommodate estate freeze transactions. ...

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5 November 2014 External T.I. 2014-0521891E5 F- Résidence principale et copropriété-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership whether a tacit co-ownership agreement is respected is a private law issue Two common-law spouses ("A" and "B") purchased a condominium as their principal residence (the "Residence"), with their names initially registered on title, but with the name of B being removed when the mortgage was renewed – but with a “tacit agreement” that they would each continue to own a proportionate share of the Residence, and with each contributing to the expenses. ...

Consequently … the taxpayer should include in the computation of the taxpayer’s income for the 2011 taxation year a dividend equal to the additional payment received in 2011. ...

. …. Even though all or substantially all of the profits of this particular community contribution company are destined for a good cause…it will nevertheless be organized (and operated) for profit and, as such, would not qualify…. ...