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. … [T]he more Mr. X is involved in the management and/or day-to-day operations of the SENC, the less likely it is that Trust X will be considered a specified member within the meaning of subsection 248(1). ...

. … As stated in paragraph 9 of IT-357R2, a training course should be distinguished from a convention. ...

Respecting the trust beneficiary scenario, CRA stated, before concluding that “the Act allows a beneficiary of a trust, who is a member of a partnership that disposes of QSBCSs, to benefit from the capital gains deduction under subsection 110.6(2.1) if the capital gain is designated by virtue of subsection 104(21.2): [G]enerally, subsection 104(2) provides that for the purposes of the Act “a trust shall … be deemed to be in respect of the trust property an individual….” ...

. … If the move occurs after the eligible period, in this example in March 2010, the unit will not be an eligible dwelling of the individual or a qualifying relation of the individual since it will not have been ordinarily occupied during the eligible period. ...

. … It is clear to us, having regard to the provisions of elements I and J of element B of the formula in the definition of GRIP, that the MPPD Amount for a taxation year is not taken into account for purposes of the calculations. ...

CRA stated: [T]here is no taxable benefit where an employee uses an Employer's automobile to drive from his or her home to the … customer. ...

. … The [s. 53(2.1)] election generally allows the taxpayer to elect to reduce an amount that would otherwise be included in income pursuant to paragraph 12(1)(x), by reducing the adjusted cost base of the property in question by the amount so elected pursuant to paragraph 53(2)(s). ...

19 May 2010 External T.I. 2010-0357071E5 F- Crédit d'impôt pour l'achat d'une 1e habitation-- summary under Subparagraph (a)(i) Summary Under Tax Topics- Income Tax Act- Section 118.05- Subsection 118.05(1)- Qualifying Home- Paragraph (a)- Subparagraph (a)(i) given future intention test, there can be a gap between purchase and home becoming principal residence Can an individual otherwise satisfying the conditions claim the HBTC if the individual acquired a residence on December 15, 2009, but did not live in it before February 1, 2010 (and may have renovated it during that period) – and can there be a gap between the time of the home’s purchase and it becoming the individual’s principal place of residence? ...

Where the matter instead has not been previously considered by the GAAR Committee, and the GAAR is likely going to be an assessment position, the TSO will refer the matter to Headquarters prior to issuing the proposal letter – so that it would generally only issue a proposal letter if Headquarters recommends GAAR’s application. ...

. … For example, where an individual chooses the period from January 1 to December 31, 2016…[i]f the…fees were paid on December 31, 2015, they would not be eligible for the METC computation for the 2016 taxation year…. ...