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Beaudoin … 2004 DTC 2414, held that the payment of funds from an RRSP to pay a debt extinguished by the order of discharge of a bankrupt does not constitute the receipt of a benefit by the bankrupt within the meaning of subsection 146(8), since the bankrupt does not receive any money or benefit as a result of that payment. ...

. … [T]he Canadian citizen to whom you refer in your request will be able to benefit from the exemption for the gain realized on the disposition of the residence located in France to the extent that a person with French nationality whose situation in fact and in law is identical to the individual’s own could benefit from it. ...

After paraphrasing the s. 20(1)(r) wording, indicating that, to be deductible, “the contributions must relate to services rendered to that corporation as an employee” and discussing the s. 67 limitation, CRA stated: [T]hat subsection does not … restrict the contributions necessary to fund an RCA. ...

A, who held ½ of the common shares of Opco having a PUC and ACB of $100, a safe income on hand of $699,900 and a fair market value of $1,000,000, transferred his common shares to a new corporation (“Holdco”) in consideration for common shares of Holdco, with the s. 85(1) agreed amount being $300,000, thereby realizing a $299,900 capital gain for which he claimed the capital gains deduction. ...

. … Please note that the definition of a retirement compensation arrangement does not require that the contributions become the property of the person to whom they are made or that a trust be created. ...

. … While there may be arguments that the costs of obtaining a health insurance card and opening a bank account are personal costs that do not benefit the employer, there are also arguments for considering these costs as part of the reasonable costs of the president's move to Canada. ...

. … [T]he custodian of an RCA who holds a letter of credit would not be able to make the election under subsection 207.5(2). ...

For example [there would be such] benefit … if one of the conditions of remaining a capital beneficiary was to continue to be employed by Opco, so as to render services to Opco.... ...

. … [P]aragraph 248(3)(f) essentially restates what subsection 248(3) provided at the time, except that the wording is now different and cannot be interpreted as in the Construction Bérou Inc. case. ...

. … Consequently, any compensation received by a taxpayer pursuant to Article 1617 of the CCQ constitutes interest income to the taxpayer (see No. 484 v. ...