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B's death …. The cost to Mr. A of the Residence could … include the portion, if any, of the legal fees and payment to Ms. B that was incurred in connection with the acquisition of the Residence. … It is … possible that, through [the] transfer contract, Mr. ... This portion of the costs … could [not] be added to or capitalized to the cost of the Residence. ...

" See summary under s. 248(1) – salary deferral arrangement – para. ...

6 January 2003 External T.I. 2002-0173405 F- Capital Dividend Account-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(1)- Capital Dividend Account- Paragraph (a) application of transitional rules re changes in inclusion fraction including example CCRA provided an overview of the CDA computation in the context of the changes in the inclusion rates from ¾ to 2/3 to ½ (including the corporation receiving a capital gains distribution from a trust) and then dealt with a specific numerical example. ...

CRA ruled that s. 95(2)(a)(i) deemed the income of one of the FA5 Subsidiaries to be active business income, and an addition to its exempt surplus under Reg. 5907(1) – exempt earnings – s. ... Here, FA4 also held distressed debt portfolios of its own, albeit partly through a subsidiary LP – and one of the conditions for the CRA ruling was that LP qualified as a partnership for ITA purposes. ...

., by deed it was agreed that the Taxpayer would have no right of accession to the garage), CRA stated: [A]ssuming that Corporation A is owner by way of superficies of the garage … then the garage, which is used by Corporation A to earn business income, would be depreciable property if the conditions set out in the definition of "depreciable property" … are satisfied. … Thus, the garage could potentially fall into Class 1(q) of Schedule II of the Regulations.... ...

. … Consequently, to the extent that you resided in Canada at any time during the 3-month period before your start date … the allowance … that you receive while posted in that country is not required to be included in computing your income for the year in which you receive it. ...

The Settlement Agreement stated that the Settlement Amount was paid to them “in consideration of the loss of entitlement to PRBs, the alleged violation of their Charter rights and discontinuing litigation … as general damages for future loss of PRBs...” ... Accordingly, to [that] extent … subsection 6(3) … will deem the payment to be employment income in the year it is received. ...

After noting that Art. 909 states that "the price for any disposal of capital or its reinvestment [...] are capital [...]" ... It follows … that any person entitled to a capital gain or taxable capital gain resulting from the disposition of property held by a trust is a beneficiary under the trust within the meaning of subsection 248(25) and holds a "capital interest" in the trust. ...

That is, employees are not required to pay the commission …. [Such] employees … receive a discount on services (i.e., the placement of insurance) by virtue of their employment. As the CRA’s administrative position concerning discounts on merchandise and commissions from personal purchases does not apply to discounts on services, such benefits are required to be included in employment income under paragraph 6(1)(a) …. ...

CRA stated: [S]ubsection 70(5.3) … would apply … for the purpose of determining the FMV of the Foreignco A shares owned by the individual at the time of disposition [under s.] 128.1(1)(b) …. ...