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It then started leasing the property to a non-associated corporation – and then disposed of the property, thereby realizing recapture of depreciation. ...

We continue to believe that the term "person … connected with a shareholder of a particular corporation" as provided in subsection 15(2.1) may include a partnership. ...

In the course of a general discussion, CRA stated: Subsection 227(6.1) … provides for repayment of Part XIII tax paid on a loan deemed to be a dividend by virtue of paragraph 214(3)(a) if the borrower, in whose name the tax was paid, repays the loan after December 21, 1992 and the repayment was not made as part of a series of loans or other transactions and repayments. ...

. … [P]repaid expenses or expenses that are paid before they are actually incurred are not deductible in computing a taxpayer's income. ...

Where … an amount on which an income tax is payable under Part XIII was paid to an agent for or on behalf of the non-resident person who is entitled to payment without the tax having been deducted or withheld, subsection 215(3) provides that it is then the responsibility of the agent to deduct or withhold the Part XIII tax payable in respect of the amount received on behalf of the non-resident. ...

2 September 2011 Internal T.I. 2011-0419111I7 F- Programme de compensation du MESS-- summary under Paragraph 56(1)(u) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(u) social assistance payments aggregating less than $500 not required to be included in income After noting that payments made by Ministère de l'Emploi et de la Solidarité sociale (the "MESS") to individuals, who were homeless and receiving financial assistance of last-resort represented social assistance payments described in s. 56(1)(u), CRA stated: ITR subsection 233(2) provides that a T5007 return does not have to be filed in certain circumstances, including where: the payment is paid as a part of a series of payments, the total of which in the particular year does not exceed $500 …. ...

In finding that the annual dividends were not subject to Part IV tax because Opco was connected to Holdco under s. 186(4)(a), CRA stated: … Opco is controlled (otherwise than by means of a right described in paragraph 251(5)(b)) by Holdco at that time, by virtue of 186(2). ...

Turning to the deferred share issuance consideration, the Directorate noted that the shares’ market price could “fluctuate greatly,” and indicated that the TSO accordingly might: conclude that such portion of the proceeds of disposition for the Mining Properties by the Vendor is not determinable prior to the date of issuance of the shares by the Purchaser and that such portion of the proceeds of disposition would be recognized for tax purposes at the times of their issuance …. ...

The CRA is, however, prepared to consider that issue as part of an advance income tax rulings request …. ...

Since subsection 7(1.3) applies for the purposes of subdivision c of Division B of Part I …, if the disposed of security is not a [s. 7(1.1)] deferred security, subsection 47(1) applies to determine the ACB subject to any applicable adjustments pursuant to paragraph 53(1)(j). ...