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On the sale, it realized a capital gain of $50,000 and a terminal loss of $60,000 – except that, pursuant to s. 13(21.1), the capital gain became nil and the terminal loss became $10,000, so that pursuant to s. 13(21.1), the deemed proceeds of disposition of the building were $250,000. The Directorate stated: [T]he expression “that would otherwise be the transferor’s proceeds of disposition of the transferred property” used in paragraph 13(21.2)(b) means the proceeds of disposition of the building determined having regard to subsection 13(21.1) … [i.e.] $250,000 … [so that] the vendor would be deemed to own a property with a capital cost of $10,000. ...

. … [W]e do not know whether the compensation paid for the Internet fees represents an allowance or a reimbursement of actual expenses incurred. … If it is … a reimbursement of actual expenses … [and] the facts show that this Internet access is essential for the employees to perform their employment duties, we are of the view that it is unlikely that a significant taxable benefit will result to the employees from the reimbursement of the Internet and modem fees. In such a case, the reimbursement would not be included in employment income. … [S]upplies [under s. 8(1)(i)](iii)] would not include the cost of tools or equipment or amounts paid for a cell phone connection or communication licence fee. ...

., CEE (or CDE) incurred in Year 2 could be renounced effective December 31 of Year 1 and $900 of CEE (or CDE) incurred in Year 3 could be renounced effective December 31 of Year 2, CRA went on to confirm its position in 9531266 that: [T]he exercise of a right to purchase a flow-through share triggers a new flow-through share agreement and … a new "agreement in writing" is not required …. As well … the period referred to in paragraphs (a) and (b) of the definition of "flow-through share" in subsection 66(15) begins on the date of exercise of the right to purchase a flow-through share and ends 24 months after the end of the month that includes that date, unless the original written agreement relating to flow-through shares and share purchase rights (the "original agreement") provides for a shorter period. ...

. … [T]he term "group … insurance plan”… includes, in particular, accidental death and dismemberment insurance plans. Therefore, if the Insurance Coverage is a group insurance plan, we are of the view that the total amounts paid by the Employer in respect of an employee during a year of Insurance Coverage is to be included in computing the employee's income from an office or employment under paragraph 6(1)(e.1). … [T]hat the Insurance Coverage primarily benefits the Employer … is not relevant for the purposes of paragraph 6(1)(e.1). ...

CCRA stated: [T]he conversion or exchange rights attached to the newly acquired Class A shares … and permitting the exchange of such shares for Class B shares … would technically constitute a "right to acquire" the substituted property …. These conversion or exchange rights would therefore be deemed to be property identical to the Class B shares … previously disposed of by the Taxpayer. Consequently, the loss incurred by the Taxpayer and resulting from the disposition of the Class B shares … would be a "superficial loss" …. ...

CRA responded: Considering that the payments made … constitute royalties … they are therefore subject to paragraph 212(1)(d) without the need to refer to paragraph 212(1)(d)(i). ...

Consequently … [such] payments … are part of a series of periodic payments and do not constitute an eligible amount within the meaning of section 60.01. ...

In finding that the cost of the land could not be bumped under ss. 87(11)(b) and 88(1)(d), CRA noted: … IT-481... [states], " If a taxpayer acquires land on which there is standing timber (for example, freehold timberlands), such property is a timber limit.” and “Unlike land on which is located a property which qualifies for inclusion in one of the classes in Schedule II of the Regulations, land which is acquired as a part of a timber limit is depreciable under Schedule VI of the Regulations and does not exist as a separate property for purposes of the Act.” ...

In finding that the cost of the land could not be bumped under ss. 87(11)(b) and 88(1)(d) because it was depreciable property, CRA noted: … IT-481... [states], " If a taxpayer acquires land on which there is standing timber (for example, freehold timberlands), such property is a timber limit.” and “Unlike land on which is located a property which qualifies for inclusion in one of the classes in Schedule II of the Regulations, land which is acquired as a part of a timber limit is depreciable under Schedule VI of the Regulations and does not exist as a separate property for purposes of the Act.” ...

Before computing her gain under ss. 128.1(4)(b), CRA noted that the cost of her interest was deemed to be nil by s. 107(1.1), and that the ACB of her interest was to be computed under s. 107(1)(a)(ii) and s. 108(1) – cost amount – para. ...