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Where a contribution is made in respect of new or future hires comprised of unidentified individuals, most of whom are not yet employees of the employer, this requirement would not be met and the contribution would not be deductible under subsection 144.1(6) …. ...

23 March 2023 External T.I. 2023-0967391E5- Incentive for nurses to go back to practice-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) s. 56(1)(r)(i) rather than s. 5(1) applies to inducement payments made by the government directly to a prospective employee of a hospital CRA indicated that where a provincial government sponsors a program that is designed to deliver incentive payments or earnings supplements directly to eligible nurses, such amounts are included in their income under s. 56(1)(r)(i) (“earnings supplements provided under a [government-sponsored] project … to encourage individuals to obtain or keep employment”) whereas if it sponsors a program designed to have employers deliver the payments directly to them, such amounts are included in their employment income under s. 5(1). ...

After noting that the (apparently Quebec) statutory provisions governing an IMB are similar to those governing a CBCA corporation, including providing that the IMB is a legal person (“personne morale”), has limited liability, except in relation to certain borrowings, has a board of directors and is governed by by-laws and resolutions – and the interests in it carry voting rights, CRA concluded that such an IMB qualifies as a corporation. ...

For general guidance on when a modification to the rights and privileges attached to a share may, or may not, result in a disposition, see … IT-448 [paras. 9-16]. ...

…[I]f it can be shown that there is a sufficiently clear connection between the death of the deceased parent and the disposition of the housing unit by the child beneficiary, then it may be possible to conclude that the disposition of the housing unit by the child beneficiary can reasonably be considered to have occurred due to the deceased parent’s death, and the gain realized on the disposition would not be deemed to be business income by virtue of the application of subsection 12(12) …. ...

. … Where it can be established that a taxpayer has disposed of a housing unit located in Canada, which was owned for less than 365 consecutive days, due to or in anticipation of the inability or lack of means to pay their debts as they become due, then the housing unit will not be considered a flipped property. ...

Accordingly … the individual may include charitable gifts made in the five previous taxation years, to the extent such gifts were not included in computing the individual’s charitable donation tax credit of those prior years, and subject to the limits described in section 118.1 of the Act. ...

After indicating that s. 56(1)(a)(i) applies to any amount received by a taxpayer in the year as, on account or in lieu of payment of, or in satisfaction of, a superannuation or pension benefit even if it is in the nature of a single payment, and that “s. 56(1)(a)(i) … applies equally to benefits from a foreign pension plan that are attributable to services rendered while the individual was not a resident of Canada,” CRA stated: In accordance with Article 18(1) of the [Canada-Chile] Treaty, pensions arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in the Contracting State in which they arise. ...

The proportion of 70% of the salary earned by the Physician could be considered to be situated on the Reserve and would therefore be exempt from tax …. ...

CRA indicated that to the extent that the Government Assistance received by Aco was in respect of the acquisition of depreciable property (or land), s. 13(7.1) (or s. 53(2)(k)) will deem that amount to reduce the capital cost of the depreciable property (or land) – without any inclusion under s. 12(1)(x) pursuant to s.12(1)(x)(vi) and without any election required. ...