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" … [A] member of a non-profit organization can make a loan to a NPO without jeopardizing the status of the NPO, even if the member, as a creditor, receives interest on its debt to the extent that the interest rate on its claim is reasonable. ...

. … If, on the other hand, the CCA relates more to the business as a whole (i.e. related to reported income and undeclared income), we are of the view that it would not be wholly applicable to undeclared income and would not be allowed as a deduction for the purpose of calculating the penalty. ...

. … [T]he Charities Directorate…have advised us that… the performance of XX services by the Charity to Newco would be a business that is not a related business. ...

. … Mr. B's income will not be considered in setting the CCTB for the months before July 2012 since paragraph 122.62(7) (b) applies only to a month that begins after a change in marital status. ...

This combined value should be included in Category 6 of Form T1135, " Other property outside of Canada. ...

X would also, by virtue of subparagraph 251.1(4)(d)(i), be a majority interest beneficiary of Trust B… … Trust A and Trust B would thus be affiliated…by virtue of subparagraph 251.1(1)(h)(i)…. ...

. … [or that the] Proposed Transactions… will have any material impact on the trading price of the shares of the capital stock of Ultimate Parentco or the value of the options held by the Optionholders. ...

CRA responded: [T]he elements applied to determine the proceeds of disposition of the building according to the calculation rules set out in paragraph 13(21.1)(a) … are, inter alia, the fair market value of the land immediately before its disposition and its cost amount to the vendor. ...

. … If instead of selling the shares to you and your wife, the Shareholder had sold the shares of the Corporation to Holdco and received a note, subsection 84.1(1)(b) of the Act might apply to deem the Shareholder to have received a dividend on the disposition of the shares. ...

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