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. … [A] distribution of income from a SIFT Trust is deemed to be a dividend pursuant to subsection 104(16)… and is similarly treated as a dividend for the purposes of the Treaty pursuant to the 2007 Protocol Annex B in regards to paragraph 3 of article X. ...

After noting that the contract with the union “must show that the contributions were paid pursuant to a PHSP within the meaning of section 20.01,” CRA stated: [A] contribution to a plan that qualifies as a PHSP could result in a deduction in computing the income from a business of the individual, who is a self-employed business owner, if all the conditions set out in subsection 20.01(1) were also met and to the extent that such an expense was reasonable in the circumstances. ­ ...

. … In order to determine the place where an Indian lives, we usually analyze whether the Indian lives on a reserve, in a domestic establishment that is his or her main place of residence and the center of his or her daily activities. ...

In the course of general comments, CRA stated: [T]he words "in respect of" [in s. 248(1) – "retiring allowance"] have been held… to imply a connection between the loss of employment and the subsequent receipt, where the primary purpose of the receipt was compensation for the loss of employment. ...

12 January 2015 Internal T.I. 2014-0560421I7- FX losses on CFA wind-up-- summary under Subsection 40(3.6) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.6) s. 40(3.6) not specifically ousted on s. 88(3) winding-up – but no affiliation after disposition In 2014-0538591I7, the Directorate indicated that s. 40(3.6) did not apply to deny a loss realized on the winding-up of a controlled foreign affiliate because (1) s. 69(5)(d) specifically ousts the application of s. 40(3.6) respecting property (the CFA's shares) disposed of on a winding-up, and (2) it is unlikely that under the foreign corporate law the CFA would be considered to still exist immediately after that disposition. ...

. … Situation 2 Similarly, the CRA considers that the balance owing under the hypothec loan assumed by Child in the circumstances constitutes "an amount payable a property acquired"…. ...

Thus … subsections 15(1), 212(2) and paragraph 214(3)(a) would be likely to subject the non-resident to Part XIII tax. ...

. … In the situation you described, if the NCPI is lower than the premiums payable, it does not seem reasonable to conclude that the total amount of the NCPI for the year would be deductible by virtue of paragraph 20(1)(e.2) in computing the income of the corporation. ...

28 April 2015 External T.I. 2015-0566011E5- Whether s. 16.1 applies to a transport truck-- summary under Subsection 16.1(1) Summary Under Tax Topics- Income Tax Act- Section 16.1- Subsection 16.1(1) identification of lease based on legal substance/no election for transport truck Before concluding that "since a transport truck would be considered exempt property, a lessee and a lessor would not be entitled to elect under section 16.1…[so that] the lessee would not be entitled to deduct CCA on this vehicle, " CRA stated: As noted in Income Tax Technical News ITTN No. 21, it is our view that the determination of whether a contract is a lease or a sale for income tax purposes is based on the legal relationships created by the terms of the particular agreement, rather than the underlying economic reality. ...

However, where after entering into the contract with Canco, USCoinstead subcontracts a portion of the work to a Canadian subsidiary of USCo or an arm's length Canadian company, USCo will not be considered to have a PE in Canada provided such Canadian company is paid an arm's length fee – and similarly, if a US professional firm subcontracts part of its consulting contract with Canco to an arm's length Canadian professional partnership. ...