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. … As indicated in paragraph 2.58 of … S1-F3-C2 … paragraph 45(1)(c) applies where the partial change in use of the property is substantial and of a more permanent nature. ...

. … Example 2 … Mr. A is present in Canada for 212 days in 2015, and the income of the partnership derived from his services is more than 50% of the gross active business revenue of the partnership ($200,000 / $350,000 = 57.14%) during those 212 days. ...

CRA responded: In general, a request for a revision to capital cost allowance claimed on property held by a partnership may be granted if all the conditions in paragraph 10 of … IC84-1... are satisfied by all members of the partnership. ... Such request will not be allowed … where … the Minister has issued a notice of determination … to one or more members. ...

19 November 2009 External T.I. 2007-0257251E5 F- Assurance-vie-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) s. 15(1) benefit where sub is policyholder and premium payer and parent is beneficiary – but not for reverse The parent corporation is the beneficiary of a life insurance policy while its subsidiary is the policyholder and pays the premiums. ... The above interpretation represents a change in position from …. 2004-006546 … and will apply as of calendar year 2010. … [W]here a parent corporation pays the premiums for a life insurance policy that it owns and of which the subsidiary is a beneficiary, there is no benefit to the shareholder under subsection 15(1). ...

. … IT-169 … addresses situations where the CRA determines that the FMV is higher or lower than the price otherwise determined by the parties to an agreement. Consequently … this Bulletin does not apply in this situation. [I]t is impossible … to comment as to its retroactive effect to the day of the initial transaction, since we do not have all the particulars …. [I]f it were appropriate to retroactively adjust the sale price, the CRA could apply subsection 152(4.2) in respect of taxation years already assessed … [but the] taxpayer must satisfy the five conditions for the CRA to agree to a reassessment giving rise to a refund. ...

After noting that this structure appeared to be intended to maximize the small business deductions by the five managementcos, CRA stated: According … Hughes Homes … 98 DTC 1082 … taxpayers have the burden of demonstrating that the fundamental reasons for the existence of the corporations are not tax-related. … [I]t seems unlikely that the corporate structure was put in place by the Individuals for reasons other than tax: … an operating corporation is created and used for each of the projects involving a real business risk; the payment of management fees to the management corporations instead of the payment of dividends (if the Operator had paid dividends, the management corporations would have been specified investment business corporations); … 4 out of 5 of the individuals are related by blood. ...

B cannot claim the children's amount in respect of any of her children since …she is not entitled to the wholly dependent person credit in respect of them and … none of the children ordinarily reside throughout the year with her and another parent. … [I]t is Mr. A who would be entitled to the child amount under paragraph 118(1)(b.1) for both children … since … he would be able to claim the wholly dependent person credit for his two children if paragraph 118(4)(a) did not apply to him for the year. … [U]nder paragraph 118(4)(a), Mr. A would not be able to claim the wholly dependent person credit in respect of more than one of his children …. ...

. … IT-169 … addresses situations where the CRA determines that the FMV is higher or lower than the price otherwise determined by the parties to an agreement. Consequently … this Bulletin does not apply in this situation. [I]t is impossible … to comment as to its retroactive effect to the day of the initial transaction, since we do not have all the particulars …. ...

Was the requirement in s. 110.6(1) – qualified small business corporation share – para. (b), that “throughout the 24 months immediately preceding [February 5, 2011, the share] was not owned by anyone other than the individual or a person … related to the individual” satisfied, having regard to ss. 28 and 35 of the Interpretation Act? ... X … owned the shares … the requirement regarding the 24-month holding period of the shares would not be satisfied …. ...

The Directorate responded: Since the lump sum in this case was not paid in lieu of amounts payable periodically as described in paragraph 22 of … IT-530R … that amount is not a support amount within the meaning of subsection 56.1(4). ...