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However, paragraph 6(1)(l) … allows a benefit relating to the operation of an automobile to be included in the income of an employee of a member of a partnership since the employee enjoys the benefit because of the employee’s employment. ...

Consequently, we are of the view that paragraph 67.1(2)(c) would apply in those cases …. ...

24 May 2001 External T.I. 2001-0069045- SHORT SALE AND IDENTICAL PROPERTIES-- summary under Subsection 47(1) Summary Under Tax Topics- Income Tax Act- Section 47- Subsection 47(1) "... ...

Profit- Short Sales "... We would consider a short sale entered into in order to hedge a taxpayer's position with respect to identical shares held on capital account to be a short sale that is on capital account. ...

In rejecting the retroactive application of this provision, the Directorate stated: Although an order dated after April 1997 may deem or stipulate that child support amounts payable or receivable after that date will be subject to the pre-May 1997 support rules … we are of the view that such tax consequences do not arise because an order has so stipulated. ...

Regarding the resulting disposition of the spousal beneficiary’s income interest, it indicated that there would be no amount to include in the beneficiary’s income pursuant to s. 106(2) as s. 106(3) would apply – but s. 106(3) would have no adverse consequences assuming that the property distributed was cash. ...

16 August 2001 Internal T.I. 2001-0079317 F- RESIDENCE PRINCIPALE DEMI-HECTARE-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence- Paragraph (e) exemption could be claimed only for one lot/ CCRA does not normally challenge contribution to enjoyment of residence of under ½ hectare if no commercial use The taxpayer acquired a lot on which he constructed a residence and also used in part for business purposes and also acquired an adjoining lot on which he erected buildings used for business purposes. ...

In addition … an amount declared by a cooperative to be a patronage dividend to a member, computed on the basis of the volume of work performed directly or indirectly by that member for the cooperative, would be a deductible amount pursuant to subsection 135(1) since it would meet the definition of "allocation in proportion to patronage". ...

CCRA responded: [A] designation filed by a corporation pursuant to paragraph 88(1)(d) in its return of income under Part I of the Act for its taxation year in which its subsidiary was wound-up, in a situation similar to the one … described, could not be considered invalid solely because the amount designated by the parent corporation was overstated. ...

Furthermore … the damages do not represent employment income. The amounts received for material and moral damages would therefore not be taxable. ...