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After noting that “subsection 8(5) … provides that professional or malpractice liability insurance that is necessary to maintain a professional status recognized by statute is deductible in computing employment income,” CCRA went on to find that the liabilities here were not deductible in computing the professional’s employment income, stating: While you are otherwise of the view that the payment of damages incurred by Professional is tied to the purchase of his personal insurance and that the Professional cannot practise his profession through the corporation without incurring professional liability, we are of the view that subsection 8(2) limits the amounts that a taxpayer may claim in computing employment income if they are not specifically provided for in section 8. ...

The fact that the Centre requires the educational staff to take their meals in the presence of the children or that the administrative staff must perform various tasks during their breaks does not change the fact that a meal constitutes an employee's living expenses and that the payment of those expenses by the employer gives rise to a taxable benefit …. ...

Consequently, the fact that no provincial tax was paid by the Trust in respect of the dividend received … cannot, in our view, trigger the application of the GAAR. ...

Thus, the "Payroll Taxes" and "Social Security Taxes" in this situation must be considered "non-business income taxes" …. ...

23 September 2003 External T.I. 2002-0172175 F- Arrangements Funérailles- Provision 20(1)m)-- summary under Paragraph 12(1)(a) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(a) prepaid funeral amounts which a funeral home was not required to hold in trust were s. 9, not s. 12(1)(a), income Regarding the 10% portion of prepaid funeral amounts which a Quebec funeral home is permitted to use in its operations rather than being required to hold in trust, CCRA stated: The 10% amount is to be included in the income of the funeral arrangement vendor pursuant to section 9, rather than pursuant to paragraph 12(1)(a), and the reserve pursuant to paragraph 20(1)(m) cannot be claimed in respect of an amount included pursuant to section 9, since it has the nature and character of income …. ...

In addition, as noted in Shell Canada … "Where an interest rate is established in a market of lenders and borrowers acting at arms' length from each other, it is generally a reasonable rate.” ...

CCRA responded: Even if the withdrawal is not referred to as a "policy loan" under the terms and conditions of the policy, this does not mean that the withdrawal is not a "policy loan" …. ...

As stated in Shell, "[w]here an interest rate is established in a market of lenders and borrowers acting at arm’s length from each other, it is generally a reasonable rate… ". ...

The Directorate stated: [U]nder the terms of subsection 231.5(1) … where, pursuant to sections 231.1 and 231.2, electronic records (such electronic records being "records" within the meaning of the definition of "record" in section 231 and the definition of "record" in subsection 248(1)) are being audited or reviewed or produced, the person who is doing the auditing or reviewing, or to whom the production is made, or any CCRA official, may make or cause to be made electronic copies of them. ...

Where the buying power of money increases, the debtor must treat the reduction in the amount due under an indexed debt instrument as interest that the debtor received or was entitled to receive in the year – and the holder of the bond will be able to deduct the amount paid to the debtor. ...