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CRA stated: Since the date of the cancellation of Interpretation Bulletin IT-265R3, there have been no legislative changes or court decisions reversing … [CRA’s] position …. As a result, we are of the view that paragraphs 8 to 10 [thereof] … still represent the CRA's position with respect to deferred or instalment payments. ...

The CRA accepts that, pursuant to the tax relief measure described in paragraph 7 of Article XXI … a gift made by a Canadian resident to a U.S. 501(c)(3) organization will be an eligible gift for purposes of the deduction in computing taxable income under section 110.1 …. or a non-refundable tax credit … under section 118.1 … subject to the income limitations, described in those sections, from U.S. sources. ... [S]ince subsections 149.1(2), (3) and (4) … govern the revocation of a charity’s registered status, and not the imposition of taxes, the Canada-U.S. ... Accordingly … Article XXI[(7)] of the Canada-U.S. Treaty does not deem a U.S. 501(c)(3) organization to be a qualified donee, for purposes of subsections 149.1(2), (3) and (4) …. ...

2004 Ruling 2004-007680-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) contributions of capital // 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. ...

. … Thus … Corporation A did not become a CCPC at the time of the signing of the purchase offer made by Corporation B since it continued to be controlled by Pubco at that time. ...

CRA responded: [W]here a court orders one spouse to pay maintenance to another then, as regards the spouse to whom the court has granted the support, this is a situation respecting an entitlement a right arising out of the marriage of such spouses …. [T]he …. transfer [by X] was made under such a court order for the payment of maintenance to X and was intended to have the support granted to X under the court order be effected in in a more liquid form. ...

29 October 2013 External T.I. 2013-0501941E5- RCA transitional rule-- summary under Advantage Summary Under Tax Topics- Income Tax Act- Section 207.5- Subsection 207.5(1)- Advantage // www.parl.gc.ca/HousePublications/Publication.aspx?DocId=5765988&File=41 ">: Subsection 44(3) of Bill C-45 introduces anti-avoidance rules, s. 207.5, for RCA advantages and prohibited investments. ...

After noting that if the estate distribution occurred as part of the series in which Corporation A received its s. 84(3) dividend, the three brothers would have an increase in their interest in Corporation B described in s. 55(3)(a)(v), and with the estate distribution also constituting an s. 55(3)(a)(iii) event, CRA stated: [I]t appears … given … the jurisprudence on the concept of a series of transactions and on the interpretation of subsection 248(10), that the distribution of the shares of the capital stock of Corporation B could be part of a series of transactions in which the dividend was received by Corporation A. ...

In the situation where FA1 was required to compute its income (pursuant to Reg. 5907(1) – earnings – (a)(iii)) under Part I of the Act, CRA indicated that the interest was deductible under s. 20(1)(c) “because the borrowed funds replaced capital that…had been used by FA1 for the purpose of earning income from an active business,” whereas in the situation where the earnings were computed pursuant to (a)(i) or (iii) of the earnings definition under local tax law and the interest was non-deductible under such law, CRA simply stated that the interest would be deductible under Reg. 5907(2)(j). ...

With respect to the use test in subparagraph 110.6(1.3)(c)(ii), … IT-373R2 … states that the criterion that an asset must be used "principally" in the course of carrying on the business of farming is satisfied if more than 50% of the asset’s use is actually for that business. ...

. … [I]f … a vehicle that does not meet the definition of automobile, there is still a benefit to the employee under paragraph 6(1)(a) where the vehicle is used for personal purposes. ...