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. … In this respect, the provision of sufficient security does not constitute a payment. ...

In light of the facts … throughout the 24-month period preceding the disposition of the ABC Inc. shares by X and Y, they were not owned by anyone other than a person or corporation related to them. ...

The TSO proposed to designate pursuant to s. 80(16) the maximum amounts permitted under ss. 80(7) and (11), so that the forgiven amount would be applied first against the balance of the non-capital loss, second as to reduce ¾ of the cumulative eligible capital and third, to reduce the adjusted cost base of the related corporation shares under s. 80(11), resulting in an amount being deemed to be a capital gain from the disposition of capital property under s. 80(12). ...

A instead was the policyholder until his death, and the registered charity received the death benefit – without providing particulars. ...

. … CRA then went on to summarize s. 248(35) and to note that “subsection 248(37) excludes several types of gifts from the application of proposed subsection 248(35) but does not exclude a gift of a life insurance policy.” ...

The Directorate first stated: Although the T5003 "Tax Shelter Information Return" and the T5003 "Statement of Tax Shelter Information" slips are considered interdependent … each summary and slip is a separate information return. ...

. … [W]ith respect to meal allowances paid to employees who work outside their regular place of employment, it is necessary to determine whether the allowance is reasonable and whether it is paid while the employee is travelling in the course of performing the duties of the employee’s employment outside the municipality or metropolitan area where the employer's establishment in which the employee ordinarily works is located. ...

In 1998, the Canada Revenue Agency amended its policy …. Consequently, a facility does not include a golf club's dining room, reception rooms, conference rooms, lounges or bar so that the deduction of expenses incurred for the purchase of food and beverages at a golf club is no longer prohibited by subparagraph 18(1)(l)(i). ...

After noting that the s. 67.1(2)(f) exception applied only for purposes of s. 67.1(1), and did not override the prohibition in s. 18(1)(l), CRA went on to state: In 1998, the Canada Revenue Agency amended its policy …. ...

. … [T]he benefit determined under subsection 7(1) will be required to be added to the non-resident's employment income earned in Canada in the taxation year of the disposition of the Corporation C shares by virtue of subsections 7(1) and (1.1) and subparagraph 115(1)(a)(i). ...