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. … [Here] a deduction of $100,000 should be made because of the capital loss realized by the corporation during the “relevant period.” ...

. … In the event that a corporation's business includes the making of loans but those loans cannot be viewed as having been made in the corporation's ordinary business of lending money, it is our view that those same loans cannot be considered as "debts that arose in the ordinary course of the creditor's business".... ...

. … It is the Department's long standing practice not to regard an offset of a shareholder's loan account debit balance against a dividend payable as part of a series of loans and repayments for purposes of paragraph 15(2)(b).... ...

. … The settlement amount paid to you was compensatory. As the Law Firm's services were acquired by you for consumption or use otherwise than in making taxable supplies for consideration, the conditions of subsection 169(1) are not met. ...

Aco then redeems the $100,000 of preferred shares (giving rise to a deemed dividend to Bco of that amount – which is not subject to s. 55(2) as Bco had full ACB in those shares), and BCo uses the redemption proceeds to discharge the note owing to A. ...

. … It does not mean that the place of activities must exist for a long time or be located in a durable building; for instance, a temporary field office on a construction site could be a fixed place of activities. ...

. … It does not mean that the place of activities must exist for a long time or be located in a durable building; for instance, a temporary field office on a construction site could be a fixed place of activities. ...

1 December 2009 External T.I. 2009-0307821E5- TFSA Contributions- Options and Warrants-- summary under Paragraph 7(1)(c) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(c) contribution to TFSA – recognition deferred until exercise by TFSA What are the tax consequences of an employee stock option being contributed to a TFSA? ...

The parent of Holdco (“Canco”) then transfers shares of directly-held foreign affiliates (“FAs”) to Holdco in consideration for Holdco shares, and Holdco then transfers such FA shares to DC (and to Newco under s. 85(1)) in consideration for an increase to its membership interest in DC by an amount equal to the FMV of such transferred shares (and for the issuance of Newco shares – with Newco then dropping down its FA shares to DC in consideration for a correlative increase in its membership interest). ...

After noting that Cummings found “that the payment of fees to a real estate broker for finding tenants and entering into new leases is generally a current expense” and that Canderel found that “in order to obtain a better or a more accurate picture of the landlord's profit, the lease incentive payments were current expenses that were deductible in the year, and which were not subject to the matching principle because they brought significant and numerous benefits immediately in the year of payment,” CRA stated: [A]ssuming, of course, that this remuneration represents an expense of a current nature … the remuneration would be deductible in the years in which it is paid. ...