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The Directorate stated: The fact that employment income from 1979 to 1981 was exempt … is not in itself determinative of the taxpayer's entitlement to the paragraph 8(1)(m) deduction in 2006. Consequently … the Contributions may be deducted in computing the taxpayer's taxable employment income in 2006 to the extent permitted by subsection 147.2(4). … Where an expense relates to both on-reserve and off-reserve income … the taxpayer must prorate the expense in question to determine the taxpayer's net employment income that is exempt …. ...

14 June 2000 Internal T.I. 2000-0021237 F- VALEUR RELATIVE D'UN JUGEMENT-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) Agency not bound to accept an amended return based on a favourable informal TCC decision re similar facts In finding that the Agency was not bound to amend a return based on a favourable Informal Procedure judgment rendered to a taxpayer in similar circumstances, it stated: The Agency … does not automatically agree to process an amended tax return on the basis that another taxpayer has won their case in court. ... Furthermore, the Agency cannot be forced to agree to process an amended return reflecting a judgment handed down by the Tax Court of Canada under the Informal Procedure because such a judgment does not constitute binding jurisprudence according to … section 18.28 of the Tax Court of Canada Act …. ...

Regarding the resulting disposition, the Directorate stated: In the case of property forfeited by statute … the definitions of "disposition" and "proceeds of disposition" … are broad enough to include the disposition of the property at the time it is forfeited, for proceeds of disposition that are nil…. ... [Here] there was a disposition of the seized equipment … at the time the court confiscated the property pursuant to section 16 of the Controlled Drugs and Substances Act. … [T]ax treatment of such equipment dispositions should be in accordance with the Act regardless of whether they are derived from illegal activity. ...

Furthermore … had Parliament intended to exclude a winding-up from the reference to “merger” in subparagraph 40(3.5)(c)(i), it would have specifically done so by incorporating exclusionary wording to that effect, as was done in subsections 87(1), 87(8.1), 87(8.2), 89(1) and 128.2(3) … [which] carve out a winding-up …. ...

8 January 2008 Internal T.I. 2007-0254881I7 F- Amortissement d'une aire de camping-- summary under Subsection 1100(17) Summary Under Tax Topics- Income Tax Regulations- Regulation 1100- Subsection 1100(17) campground, if a business, not subject to leasing property restriction rule In finding that a campground generally would not be subject to the rental property restriction rules, the Directorate stated: [P]aragraph 7 of [IT-434R] … states that “The operation of a trailer court or campground where all services are provided, e.g., laundromat, cafeteria, swimming pool, showers, playgrounds, etc. … would be a business, but not a rental business due to the magnitude of services provided.” … [I]f a taxpayer's operation of a campground constitutes a business … it is the CRA's view that the taxpayer carrying on such a business is not restricted in the amount of the CCA deduction. ...

9 May 2022 Internal T.I. 2018-0790251I7- 45(2) election and beneficial ownership-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership a spouse could be the beneficial owner even though she did not contribute to the property's purchase / owner means beneficial owner S. 45(2) permits a taxpayer to elect to avoid a deemed disposition from a conversion of “property of the taxpayer” from personal to income-producing use. ... A person who has beneficial ownership but not legal ownership can enforce their ownership rights against the holder of legal title. … There is generally a presumption that the holder of legal title of a property is also the beneficial owner of the property, unless the facts support otherwise. It concluded: [I]f both spouses are considered to have beneficial ownership … they would both be required to file the election …. ...

20 March 2013 Internal T.I. 2013-0480201I7 F- Montants forfaitaires- XXXXXXXXXX-- summary under Paragraph 6(3)(d) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(3)- Paragraph 6(3)(d) amounts paid to workers in wage-discrimination suit that were in excess of reasonable amount for rights’ violations or non-pecuniary damages would be employment income In discussing the treatment of lump sums paid to federal employees following a finding by the Human Rights Tribunal that a discriminatory practice had been committed at their workplace and pursuant to a settlement agreement concluded with the Treasury Board, CRA stated: [I]f the amounts paid to the Workers … represent an award to compensate for or replace a source of income that would have been included in their income as employment income, these amounts could be income from an office or employment of the Workers. … However, if the evidence shows that the amounts … as damages for the violation of their rights under the Canadian Human Rights Act, they may not have to be included in the computation of the income of the Workers. ...

The Directorate stated: [A]cceding to the taxpayer’s request to amend the return filed for the particular year would require the loss carryback to be eliminated and would have no impact on the tax payable for that year … [so that] no reassessment would be required. Accordingly … the Minister may, at any time, notify again the taxpayer that no tax is payable. However, although on “receiving a request to amend a return, the Minister is required to examine the amended return and issue a reasonable decision … [w]here it would not be appropriate for the Minister to accept the taxpayer’s request to amend the return, the Minister can deny the request.” ...

The Directorate stated: [T]he expression "an expense incurred... for the purpose of providing … for an eligible child of a taxpayer, child care services " is sufficiently flexible to include mandatory registration fees that allow an eligible child access to a daycare service. ...

1 September 2015 Internal T.I. 2013-0507381I7- Transfer pricing adjustments and gross revenue-- summary under Subsection 247(2) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2) [s. 247(2) increases to gross revenues] CRA considered that an upward adjustment to a Canadian resident’s sales proceeds – but not a downward adjustment to its purchase price for goods – increased its gross revenue for provincial income allocation purposes. ...