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In addition, the fact that the obligation is held for the short, medium or long term does not change the nature of the premium …. ...

. … Where a taxpayer holds a bond as a trader or dealer, we are of the view that any loss on the disposition of the bond that is attributable to the payment of a premium will be a loss on income account. ...

21 February 2002 External T.I. 2001-0105735 F- Intérêts sur remboursement- gains en capital-- summary under Subsection 132(2) Summary Under Tax Topics- Income Tax Act- Section 132- Subsection 132(2) MFT obligation to pay tax, if unpaid, will be reduced by application of capital gains refund Before confirming that a mutual fund trust which was entitled to a capital gains refund equal to its tax payable for a year nonetheless could be subject to interest charges, CCRA stated: [T]he capital gains refund … has no impact on the application of subsections 156.1(4) and 161(1). ...

CCRA indicated that if this return of premium on death clause was ancillary to critical illness insurance, the insurance policy would be a sickness or accident insurance policy – in which case, there would be no taxable benefit under s. 6(1)(a) if it were a group sickness or accident insurance plan. ...

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. … [T]he wording of the Act would not restrict the deductibility of contributions paid between 1989 and 2001, even though they were paid after the time that triggered the payment of the first benefits in 1988. ...

CCRA stated: [W]here a payment is received by a corporation as damages pursuant to an out-of-court settlement and does not represent a death benefit paid pursuant to a corporation's rights under a life insurance policy, the payment cannot be included in computing the corporation's CDA under paragraph (d) of the definition of CDA …. ...

28 October 2002 External T.I. 2002-0117595 F- REVENU EXPERT-COMPTABLE-- summary under Nature of Income Summary Under Tax Topics- Income Tax Act- Section 9- Nature of Income accountants required to individually recognize professional income earned by them as employees of an NPO corporation In the context of a non-profit association employing chartered accountants who provide accounting and tax services to the association’s members, but with the chartered accountants billing such members for their services directly (as required by the provincial professional body) and paying over the proceeds to the association, CCRA applied its position in IT-189R2, para. 2 that if provincial law or the regulatory body for the profession precludes the practice of the profession by a corporation, income derived from the profession will normally be considered to be earned by the individual who rendered such professional services and not by a corporation – so that such billings were required to be included in the chartered accountants’ business income, but with a deduction for the value of the administrative services provided to them by the association. ...

. … [Here] there was no replacement of the original obligation by another obligation between the Corporation and the debenture holders. ...

CCRA stated: [I]f the value of goodwill varied according to the number of prescriptions sold during each period preceding that of the lease renewal, we are of the view that the position described in paragraph 5(c) … IT-462 could apply. ...