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Thus … the block size would be 100 and thus if there were 100 unitholders of the first series each holding at least 100 units, and there would have to be at least 50 unitholders of the second series, each holding at least 100 units. ...

Before indicating that such fee could be deducted in accordance with s. 20(1)(e) provided that it was “incurred in the course of borrowing money used to earn income from a business or property and that it [was] reasonable,” CRA stated: [P]aragraph 20(1)(e.1) … does not have application because the guarantee fee is paid in respect of the term of the loan rather than with respect to the year in which it is paid. ...

In that case, the vehicles must be reclassified, from that point onwards, in another Class …. ...

CCRA also indicated: [T]he reserve included in computing business income pursuant to subsection 34.2(5) for the taxation year subsequent to the year in which a taxpayer ceases to carry on business will not be included in earned income …. ...

. … In this case, the facts submitted are clearly insufficient to allow us to conclude whether or not the XXXXXXXXXX office constitutes a fixed place of business for Canco. ...

Consequently … the estate may designate the portion of the property that you occupied as your principal residence since its acquisition. ...

" … [W]here a farmer, makes application for subdivision, then subdivides the farmland and proceeds to develop it and sell lots, it is our general view that the farmland would be considered to have been converted into inventory at the time of making application to the relevant authority for approval of a plan to subdivide the land into lots for sale. ...

After repeating its position that “personal travel includes travel between the employee's home and ‘regular place of employment’,” and noting that “regular place of employment” was described in T4130 as including “a client's premises when an employee reports there daily for a six month project” and “a client's premises if the employee has to attend biweekly meetings there,” and before noting that it could only make general comments, CRA stated: If the place of business of a client of the firm constitutes a "regular place of employment " for the auditor, the travel between the auditor’s residence and the place of business of that client is considered personal travel and is therefore not considered travel "in the performance of the duties of the employee’s office or employment". ...

4 December 2018 External T.I. 2016-0670851E5- Regular Places of Employment and Personal Travel-- summary under Paragraph 6(1)(b) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b) scope of “regular place of employment" Respecting requested clarification as to when a particular work location is considered a regular place of employment for an employee, CRA stated: [T]ravel between an employee’s home, including a home office, and a regular place of employment (RPE) is generally considered personal travel …. ...

Before concluding that the interest was deductible under s. 20(1)(c)(ii), CRA referenced its position in Folio S3-F6-C1, para. 1.65 that “where a note is issued to purchase and cancel (or otherwise redeem) shares, interest expense may be deductible under subparagraph 20(1)(c)(ii),” and then stated: In a situation as such described above where there is a capitalization of a portion of a corporation's accumulated profits as stated capital of the preferred shares of the capital stock of the corporation, the CRA is of the view that the "capital" attributable to the preferred shares for the purpose of applying the "fill the hole" concept … generally corresponds to the paid-up capital of the shares. ...