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X commences to use his condominium exclusively for personal purposes, would he be able to use the s. 45(3) election to defer the taxation of the capital gain until the actual sale of his property if he designates the condominium as his principal residence – and would the answer change if Mr. ... However … where Mr. X … used the property entirely for the purpose of earning income and … at a later time began to use it exclusively for personal purposes … the taxpayer would be able to rely on the subsection 45(3) election if subsection 45(4) does not apply and the condominium becomes the taxpayer's "principal residence" …. ...

After finding that such amounts were not a reserve described in s. 181.2(3)(c), and in finding that they were includible in taxable capital pursuant to s. 181.2(3)(b) as “advances,” the Directorate stated: The word "advance" … denotes, inter alia, the lending of money or the payment of an amount against the price of a contract for services or goods, paid before the contract is performed, the services rendered or the goods delivered. … [I]n this context … the consideration to be received by customers is … the XXXXXXXXXX service offered by the corporation. ...

In finding that the Allowance might in fact be a reimbursement, in which case, it likely would be non-taxable, CRA stated: [E]ven if the employer uses the term "allowance" to refer to the payment made to an employee, it is possible that … the allowance may be a reimbursement of expenses. Consequently, if … the Allowance is, for example, based on an estimate of the travel and accommodation costs that the Employee will incur during the training period, or that Mr. A must show the Employer how the Allowance was spent, then it may be that the Allowance is more of an expense reimbursement and not a taxable allowance pursuant to paragraph 6(1)(b). … [G]iven that … the training appears to be primarily for the benefit of the Employer, the $15,500 Allowance may be non-taxable to Mr. ...

. … Since … the Royalty payments will not be remitted to or received in the UK and accordingly are not taxable in the UK, X will not be entitled to the benefits of Article 12(2) …. ...

CRA responded: [P]aragraph (c) … will … be satisfied since the related business (i.e. the business carried on by Partnership AB) will also constitute the business of the Partnercos. ... B other than a business of the Partnercos. … Under the assumption that the conditions in paragraphs (a) and (b) of the excluded shares definition are also satisfied, the shares held by Mrs. ...

Therefore … the Individual would be considered to have received the benefit (i.e., the Commuted Value) in the year of the Transfer and would be required to include the amount of the benefit in income under subparagraph 56(1)(a)(i). … Furthermore … even if the constructive receipt doctrine were found not to apply, subsection 56(2) would apply to include the Commuted Value in the Individual’s income under subparagraph 56(1)(a)(i) in the year of the Transfer. ...

In this regard, CRA stated: Where an employer does not reimburse an employee for employment-related electricity costs paid by the employee and the employment-related electricity costs can be established, the costs may be deducted by the employee as motor vehicle travel expenses if all of the conditions in paragraph 8(1)(h.1) … are met …: was normally required to carry out his or her employment duties away from the employer’s place of business (or in different places); was required by the contract of employment to pay such expenses; and did not receive a non-taxable allowance or reimbursement in respect of the motor vehicle expenses. …[S]ubsection 8(10) … requires the employee to obtain a completed and signed Form T2200 … ...

. … Folio S1-F1-C1 … states that, notwithstanding several exceptions, “eligible medical expenses are not restricted to those paid in Canada or for medical services provided in Canada”. Whether ‘all or substantially all’ of the premiums paid under the … plan relate to medical expenses that are eligible for the …METC … is a question of fact and can only be determined by the insurer of the plan. ...

If this benefit is provided to the incorporated employee in the incorporated employee’s capacity as an employee … the cost of the benefit comprises the personal use portion of the automobile lease costs. Consequently, these expenses would be deductible in computing the income of the PSB corporation by virtue of subparagraph 18(1)(p)(ii) to the extent that such leasing costs would otherwise be deductible if the corporation's income were from a business other than a PSB. … If this benefit is provided to the incorporated employee in the incorporated employee’s capacity as a shareholder, the cost of the benefit is not deductible in computing the income of the PSB corporation … since it would not, if the corporation's income were from a business other than a PSB, be deductible in computing its income. ... Respecting CCA claims, CRA stated: [A] capital cost allowance amount is not the cost of a benefit …[and] is not deductible in computing the income of a PSB corporation under subparagraph 18(1)(p)(ii). … However … capital cost allowance may be deducted in computing the income of the PSB corporation by virtue of subparagraph 18(1)(p)(iii) where such an amount would otherwise have been deductible by virtue of paragraphs 8(1)(f) and 8(1)(j)(ii), having regard to subsections 8(4), 8(10) and 8(13) …. ...

Whether a specific expense is a mandatory computer service fee is a question of fact …. In general … fees paid for services rendered by the computer department are allowable fees if they are mandatory fees. ...