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., 1996 J.Q. no. 5103 … established that support and custody judgments lose all effect when the parents resume living together … [and] that these judgments would not take effect if the parents subsequently separated again. … Since the amounts were paid under a new agreement, which was only a verbal agreement between the parties, that arose following the second separation, the amounts paid by Monsieur do not meet the definition of "support amount" in subsection 56.1(4) …. ...

Customized remittance vouchers for businesses can be obtained quickly and easily through the CRA Web site … or through the "My Business Account" service …. ...

CRA stated: PARENT would … not be eligible for a deduction under subsection 91(5) … with respect to the dividend received from CFA2, given that the ACB of the CFA2 shares for PARENT was not subject to any adjustment under paragraph 92(1)(a) …. ...

Is CRA is bound by the presumption in s. 6 of the Act respecting the professional status and conditions of engagement of performing, recording and film artists (Quebec)- that for the purposes of that Act, an artist who regularly binds himself to one or several producers by way of engagement contracts pertaining to specified performances is deemed to practise an art on the artist’s own account – where the artist otherwise would be regarded as an employee? CRA responded: As stated in section 6 … the presumption has effect only for the purposes of that Act and therefore does not affect the purposes of the application of the Income Tax Act. Consequently … despite the presumption contained in section 6 … the tax status of performing, recording and film artists will be determined by the criteria usually applied by the CRA. ...

. … Desjardins J.A. of the Federal Court of Appeal stated that the former wording of subsection 248(3) allowed the concepts of beneficial ownership (possession, use and risk) to be applied to the leasing contracts at issue. In our view, this interpretation is contrary to Parliament's intention, which was to consider certain civil law situations equivalent to beneficial ownership in order to remedy certain problems created by the non-existence of that concept in Quebec civil law. … [T]he Federal Court of Appeal emphasized the importance of applying the Act uniformly across Canada, regardless of the legal system. The Court therefore concluded that the position in … IT-233R, as it existed at the time … applied to all taxpayers at that time. ...

7 October 2021 APFF Roundtable Q. 14, 2021-0901041C6 F- Meaning of Any consideration received by Donee-- summary under Paragraph 118.1(13)(c) Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(13)- Paragraph 118.1(13)(c) “consideration … received” in s. 118.1(13)(c) includes a s. 84(3) deemed dividend Under s. 118.1(13)(c), where a qualified donee that disposes of non-qualifying securities (“NQS”) that were gifted to it, the amount of the original gift will be deemed in some circumstances to equal the fair market value of the “consideration” received by the donee for that subsequent disposition. ... CRA responded: [G]enerally speaking, and in the absence of any indication to the contrary … the notion of "consideration" is broad enough to encompass any amount, good or service received upon the disposition of property. The CRA is of the view that the word "consideration" in the phrase "fair market value of any consideration … received by the donee for the disposition … of the security" in paragraph 118.1(13)(c) must be given the broad meaning generally accepted in the jurisprudence. ...

Finally, although the relative value of labour in relation to the value of the total property suggests that labour is a capital expenditure … this ratio is not necessarily decisive …. [T]he fact that work was not carried out earlier does not change the nature of the work when it is finished, regardless of its total cost. … In Méthé [86 DTC 1364], the TCC stated that the increase in rental income was the most conclusive evidence that the work done by the taxpayer resulted in a nearly new building and not the same original building. … Thus, the increase in gross rental revenues in this case, for the years following the work, will be a factor that will allow us to conclude whether the expenses incurred by the taxpayers were current or capital in nature. ...

. … The expenses covered by our position … include expenses that a parent may be obligated to pay as a result of a parental obligation. ... Further, in that situation, the parents would not be taxed pursuant to subsection 105(1) by virtue of the payment of those expenses by the trust. … Among the examples mentioned, we are of the view that tuition fees for the education of a minor beneficiary or fees paid at a summer camp attended by the minor beneficiary would relate to an expense incurred for the child, the payment of which, subject to the other conditions stated in Income Tax Technical News, No. 11, would be considered to be payment of income to the child. On the other hand, with respect to the acquisition of a car, one would have to examine the relevant facts to determine whether the acquisition is for the benefit of the minor child or for the benefit of another person. … ...

. … [A]n amount does not have to be assessed to be an amount referred to in subsection 159(2). Thus, an assessment in respect of the Trust does not have to be issued in order to assess the Legal Representatives pursuant to subsection 159(3). … [I]t is reasonable to consider that … the issuance of the clearance certificate by the CRA does not relieve the Legal Representatives of their personal liability pursuant to subsection 159(3). It is all the more important to consider that, at the time of the request to the CRA for the clearance certificate, the Legal Representatives did not disclose any information relating to the undeclared capital gains. … [P]aragraph 159(3)(b) provides that the Minister may, at any time, assess a legal representative for any amount payable pursuant to that subsection without regard to the normal reassessment period. ...

. … Second, the replacement property must have been acquired for the same or similar use as the former property. If the former property is a secondary residence, this requirement could be satisfied if the new property qualifies as personal-use property …. The geographic location of the "replacement property" is generally not a determining factor …. ...