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. … As a result [of s. 9(3)], the appreciation in the value of a property that is capital property (as defined in section 54) is not in itself a source of income that is property. ...

CRA referenced the s. 6(6)(b) exclusion to s. 6(1)(a), and stated: As indicated in … 2004-0059521E5 and 2008-0291081E5, that exclusion does not apply to transportation assistance that the employee received for travel between the special work site and a temporary residence of the employee that is the employee’s principal place of residence. ...

A scholarship awarded to a student to complete a research project leading to a Ph.D. and other amounts received by the student to cover the student’s maintenance and study expenses while working on their doctoral dissertation would normally qualify as a research grant within the meaning of paragraph 56(1)(o) …. ...

CRA confirmed this result, and also stated: 1- As the Magdalen Islands were a "prescribed zone" for the taxation years 1988 to 1994; 2- If the individual met all the conditions for the application of section 110.7; and 3- Since the Magdalen Islands have been an "intermediate zone" since the 1988 taxation year; the "specified percentage" for deductions for residents of prescribed zones would be: 100% for taxation years between 1988 and 1992; 66 2/3 % for the 1993 taxation year; and 50% for the 1994 and subsequent taxation years. ...

28 October 2010 Internal T.I. 2010-0376041I7 F- Contrat d'acquisition ou de location-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A lease where lessee got benefits of ownership even if it didn’t acquire title not necessarily a lease Motor vehicle lease agreements provide that the lessee will automatically acquire ownership after making specified rent payment, and with the payment of an often nominal residual value – and if the lessee decides not to acquire, any excess of the sales proceeds are credited to it by the lessor After indicating that generally “re-characterization of legal relationships is only possible where a taxpayer's designation of the transaction does not adequately reflect its true legal effects,” CRA stated: [W]hether a contract is a purchase contract or a lease contract should be resolved primarily on the basis of the legal relationships created by the terms of the agreement. ...

21 September 2010 Internal T.I. 2010-0377011I7 F- Dépenses de vêtements- travailleur indépendant-- summary under Paragraph 18(1)(h) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(h) no deduction to self-employed welder for work boots and fire-resistant clothing In finding that the cost to a self-employed welder of purchasing steel-toed work boots and fire-resistant clothing could not be deducted in computing his business income, CRA stated: [W]here a taxpayer acquires clothing that can be used in both the taxpayer's business and personal activities … the expense is a personal or living expense that is not deductible by reason of paragraph 18(1)(h). ...

. … Our position might be different if these boots and clothing were used by the self-employed worker only in the course of performing the worker’s welding activities. ...

After quoting from the definition of "general-purpose electronic data processing equipment" including the requirement that there be “an internally stored computer program that … can be altered by the user of the equipment,” CRA stated that given that there was “no indication that the user of the property can modify the computer program stored therein,” the device did not appear to qualify. ...

CRA stated: [T]o the extent that Dividend A was a dividend legally distinct from Dividend B and to the extent that Dividend A was designated as an eligible dividend under subsection 89(14), the fact that only one cheque is issued by Opco in respect of the payment of both Dividend A and Dividend B would not prevent Dividend A from qualifying as an "eligible dividend" …. ...

Since a building does not have the same physical characteristics as a parking lot, it is our view that the building … does not satisfy the condition in paragraph 44(5)(a.1) even though both the parking lot and the building generate rental income. ...