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. … If the automobile benefit was conferred on Son…in his capacity of employee of the corporation and Son included the value of the benefit in computing his income from employment…no amount would be included in computing income of his father under subsection 15(1)…. ...

. …. If, in the case described, there in fact is an allocation of capital gains of the SEC to its partners, we believe it would be difficult to maintain that they do not retain their character in the hands of the latter, including the Limited Partner. ...

After summarizing it two-step approach to entity classification, CRA stated: The CRA has not established a list of essential features that a foreign Entity must possess to be classified in any of the different categories of recognized Entities …. ...

See summary under s. 55(1) – distribution. ...

On this basis, while the exempt surplus of FA3 would be reduced to $25, … Merged FA's opening exempt surplus is $200. ...

Therefore … if sales taxes are included in the lease charges, the consumption tax amounts recovered in respect of the lease of the vehicle will be included in element E in the formulas under paragraphs 67.3(c) and (d) for the purpose of calculating the limitation in section 67.3. ...

…[T]he sole fact of the non-resident taxpayer being in a conjugal relationship with the Other Person would not make him a resident of Canada …. ...

. … Canco was deemed to realize a gain in Year 3… equal [to] the total of amounts deducted by Canco under paragraph 113(1)(d) in respect of Forco dividends received through LP that were paid out of Forco's pre-acquisition surplus, less any foreign tax paid in respect of Canco's share of those dividends. ...

. … [I]n 2009-033576, there was no withdrawal from the RRSP. ...

These sums must be reported on a T4A slip …. ...