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CCRA ruled: The insurance claim payment that relates to the indemnification of an account receivable that became a bad debt does not constitute the recovery of the bad debt for the purposes of subsection 231(3) …. ...

S3-F3-C1- Replacement Property-- summary under Paragraph 44(1)(c) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(1)- Paragraph 44(1)(c) Replacement property can be acquired at any time after notice of intention to take 1.11 Where … a former property was taken under statutory authority, the replacement property can be acquired at any time after a taxpayer receives notice of an intention to take the property under statutory authority and before the time noted in [s. 44(1)(c)]. ...

Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025-- summary under Subsection 15(2.17) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.17) Overview 1.18 … In very general terms, where the conditions set out in subsection 15(2.16) are met, subsection 15(2.17) deems that the particular corporation or partnership made a loan to the borrower for the purposes of sections 15 and 80.4, in an amount equal to the funding indirectly provided. ...

IC72-17R6 "Procedures concerning the disposition of taxable Canadian property by non-residents of Canada – Section 116" September 29, 2011 ...

29 July 1992 Memorandum (Tax Window, No. 21, p. 4, ¶2037)-- summary under Subsection 249(4) Summary Under Tax Topics- Income Tax Act- Section 249- Subsection 249(4) Two unrelated individuals each holding ½ of the shares of a corporation will not be considered to act in concert simply because the consent of both is required before the corporation can undertake any action. ...

. … In this case the individual being sued is the recipient as he agreed to pay the suing lawyer…. ...

19 September 2015 STEP Roundtable, Q.5-- summary under Subsection 104(13.2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(13.2) late s. 104(13.2) designation to utilize capital loss carryback CRA accepts that if a trust has pushed out income to its beneficiaries in Year 1 and in, say, Year 3, realizes a non-capital or capital loss, it can amend its return for Year 1 to include income, which it previously had pushed out to its beneficiaries, in its income, thereby resulting in net income that can be offset by a loss carryback – and with the beneficiaries' returns then being reassessed to exclude the previous inclusion under s. 104(13). ...

. … For this reason, one is to assume that the expenses would need to be submitted to the insurance company before the amount can be considered by the Canada Revenue Agency…. ...

. … [I]nterest earned from [for example, a manufacturer's] bank accounts and Guaranteed Investment Certificates is considered to be interest with respect to making advances, lending money or granting credit and is included in the calculation of the de minimis threshold test under paragraph 149(1)(c). ...

Eligible spin-offs-- summary under Subsection 86.1(2) Summary Under Tax Topics- Income Tax Act- Section 86.1- Subsection 86.1(2) // www.cra-arc.gc.ca/tx/bsnss/tpcs/frgncrp-eng.html ">"Information for foreign corporations" 6 March 2012: Respecting the requirement in s. 86.1(2)(b) that the distribution consist only of shares, CRA states: If the shares distributed in the course of the spin-off had rights to purchase other shares attached to them, the corporation should confirm that the rights plan was established for bona fide business purposes other than to obtain a tax benefit. ...