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. … [A]n issuer may not agree to transfer property to a RRIF trust where the property will not provide the necessary liquidity to make the minimum payments. ...

14 January 2004 External T.I. 2003-0026011E5 F- Contrat à terme sur indice boursier-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base unrealized gains or losses on stock index futures contracts not included in the ACB of such property Regarding whether unrealized gains or losses on stock index futures contracts should be taken into account in determining the "cost amount" of a property for purposes of former Part XI, CCRA stated: The Act … states that the cost amount of a property that is capital property is the adjusted cost base of the property, which generally reflects the costs or expenses incurred to acquire the property. ...

. … [W]hen computing the capital gain resulting from such a disposition, the costs incurred to receive such proceeds of disposition (such as legal fees and appraisal fees that have not been reimbursed) would be expenses incurred for the purpose of making the disposition and would be deductible when computing such gain. ...

The Directorate, in noting that “[i]t is possible that the person paying salary or wages is not the employer,” repeated the statement in Mollenhauer “that subsection 153(1) … does not speak of whether persons doing the paying are employers or not,” and went on to find that the individuals likely were employees of Cco, so that the charges from Bco for their salaries likely could be included in the “cost of labour” of Cco under Reg. 5202. ...

Consequently, the functions or services performed by the subcontractors do not fall within the definition of "cost of labour" …. ...

. … In determining the fair market value of a residual capital interest in a trust, the Agency does not advocate a particular mortality table. ...

15 April 2004 Internal T.I. 2004-0062451I7 F- Résidence principale-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence- Paragraph (c) no need to file form for principal residence portion of disposed-of property if it was fully exempted A taxpayer disposed of land in excess of ½ a hectare, did not file a Form 2091, did not report any capital gain, and on audit was unable to demonstrate that the excess land was necessary for the use and enjoyment of the residence, so that there was a capital gain on the disposition of such excess land. ...

23 April 2004 External T.I. 2004-0057231E5- Premium Deductible under 146(5)-- summary under Premium Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(1)- Premium mortgage payments made by the annuitant to the annuitant’s RRSP were not premiums CRA noted that, subject to the specified exceptions:,,, where an 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) …. ...

CRA responded: [S]ince the taxpayer is an individual … only clause 40(2)(a)(ii)(A) could apply if the corporation was controlled by one of the former partners who became a shareholder of the corporation immediately after the sale. ...

Paragraph 23 of Interpretation Bulletin IT-337R4 explains the limit …. ...