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2004 Ruling 2004-007680-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) // www.bci.ca/ "> www.bci.ca): Non-capital losses of BCI are transferred to its affiliate, Bell Canada, pursuant to transactions under which a subsidiary of Bell Canada ("Bell Subco") borrows up to $17 billion on a day-light loan and uses the borrowed money to subscribe for preferred shares of a newly-incorporated subsidiary of BCI ("BCI Subco"), BCI Subco lends the money on a non-interest bearing basis to BCI, BCI lends the same funds on an interest-bearing basis (1 basis point lower than the dividend rate on the preferred shares) to Bell Subco, which pays off the day-light loan. ...

. … [Here] … it appears that the move did not occur to enable the taxpayer to be employed at a new work location for purposes of the moving expense deduction. ...

A copy of the amended T4 slips for a given taxation year must be sent to the … CRA … and all affected employees informing them that they may request an adjustment to their income tax return for the particular taxation year. ...

In commenting on the meaning of “incurred,” CRA stated: … Wawang … stated: [T]he correct question to ask, in determining whether a legal obligation is contingent at a particular point in time, is whether the legal obligation has come into existence at that time, or whether no obligation will come into existence until the occurrence of an event that may not occur. ...

13 March 2012 External T.I. 2012-0433661E5 F- Notion de dépense engagée-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense expense not incurred if obligation therefor dependent on future contingency Before noting that “the concepts of ‘outlay or expense incurred’ under paragraph 18(1)(a) can apply to expenses incurred for the purposes of the medical expense tax credit,” CRA stated: … Wawang … stated: [T]he correct question to ask, in determining whether a legal obligation is contingent at a particular point in time, is whether the legal obligation has come into existence at that time, or whether no obligation will come into existence until the occurrence of an event that may not occur. ...

The Directorate responded: In light of paragraph 18 of the Bulletin [IT-518R] … and … Stapley, we are of the view that the use of the expression "enjoyment of entertainment" refers to the act of being entertained rather than to tangible property such as a book, musical instrument or Blu Ray disc player, the use of which could potentially provide a form of entertainment. ...

In such cases, and based on … Fries … those amounts will not be required to be included in the taxpayer's income since they do not represent income from a source in Canada. ...

.-- summary under Paragraph 149.1(4)(a) Summary Under Tax Topics- Income Tax Act- Section 149.1- Subsection 149.1(4)- Paragraph 149.1(4)(a) foundation’s registration subject to revocation because it had invested in a Delaware partnership (with stated separate existence) carrying on business A Quebec private foundation, which had invested in a foreign partnership (FP) that was governed by the Delaware Revised Uniform Partnership Act (DRUPA), submitted that “the FP is a separate legal entity from its members under the statutory provisions of the … DRUPA … by virtue of which it was created and consequently it is the FP that operates the business and not the members,” so that its registration was not subject to revocation under s. 149.1(4)(a). ...

After finding that the allowances were not taxable under s. 5(1) or s. 6(3), CRA went on find that they were non-taxable as not being income from a source, stating: We also refer you to … Fries … where the [Supreme] Court determined that an amount must come from one of the sources listed in the Act to be taxable. ...

Notwithstanding our general view described above, we note that the CRA has previously applied … GAAR … in situations where mutual fund trust status was artificially achieved to facilitate abusive tax avoidance. ...