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. … IT-169 … addresses situations where the CRA determines that the FMV is higher or lower than the price otherwise determined by the parties to an agreement. Consequently … this Bulletin does not apply in this situation. [I]t is impossible … to comment as to its retroactive effect to the day of the initial transaction, since we do not have all the particulars …. ...

Was the requirement in s. 110.6(1) – qualified small business corporation share – para. (b), that “throughout the 24 months immediately preceding [February 5, 2011, the share] was not owned by anyone other than the individual or a person … related to the individual” satisfied, having regard to ss. 28 and 35 of the Interpretation Act? ... X … owned the shares … the requirement regarding the 24-month holding period of the shares would not be satisfied …. ...

The Directorate responded: Since the lump sum in this case was not paid in lieu of amounts payable periodically as described in paragraph 22 of … IT-530R … that amount is not a support amount within the meaning of subsection 56.1(4). ...

11 October 2005 External T.I. 2005-0148281E5 F- Déductibilité de dépenses-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees accounting fees in preparing consolidated financial statements generally deductible In finding that accounting fees related to the preparation by a parent of consolidated financial statements for the group were generally deductible, CRA stated: … IT-99R5 … lists legal and accounting fees for a wide range of ordinary functions. ...

11 October 2005 External T.I. 2005-0148281E5 F- Déductibilité de dépenses-- summary under Subsection 248(24) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(24) s. 248(24) does not affect deductibility of fees for preparing consolidated financials In finding that accounting fees related to the preparation by a parent of consolidated financial statements for the group were generally deductible, CRA stated: … IT-99R5 … lists legal and accounting fees for a wide range of ordinary functions. ...

. … [T]herefore … a corporation that pays certain of its directors remuneration consisting solely of shares of the corporation would not be required to deduct source deductions on the value of this remuneration in shares. ...

16 August 2022 CPAC Roundtable Q. 10, 2022-0946251C6- Home Office Expenses-- summary under Subparagraph 8(13)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(13)- Paragraph 8(13)(a)- Subparagraph 8(13)(a)(ii) s. 8(13)(a)(ii) does not extend to virtual meetings Regarding the impact of meeting clients in a home virtually, CRA stated: It is the long-standing position of the … CRA … that the term “meeting”, as used in both subparagraph 8(13)(a)(ii) and 18(12)(a)(ii) of the Act includes only face to face encounters. ...

28 February 2001 External T.I. 2000-0016765 F- All or substantially all-- summary under Clause 110.6(14)(f)(ii)(A) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(14)- Paragraph 110.6(14)(f)- Subparagraph 110.6(14)(f)(ii)- Clause 110.6(14)(f)(ii)(A) all or substantially all test in s. 110.6(14)(f)(ii)(A) is generally but not always a 90% of FMV test Regarding the meaning of the expressions “all or substantially all the assets used in an active business” in ss. 110.6(14)(f)(ii)(A) and 54.2, CCRA stated: FMV is generally the best measure for calculating “all or substantially all of the assets” of a business for the purposes of those provisions …. However … other units of measurement could apply since those provisions of the Act do not state any particular unit of measurement that must be used. ...

A taxable capital gain from the disposition of a "Canadian resource property" is therefore not included pursuant to subparagraph 115(1)(a)(iii) …. [Furthermore] … it is highly doubtful that the Right can be considered real property …. Article 900 of the Civil Code of Québec, which states that "fruits and other products of the soil may be considered to be movables … when they are the object of an act of alienation,” leads us to believe that the Right would not constitute immovable property but rather movable property. ...

After referencing the general principle that “interest expense on borrowed money used to make an interest-free loan … may be deductible … where the facts disclose that the money was borrowed for an indirect current use whose purpose was the earning of income from a business or property,” CRA stated: The CRA generally agrees that this is the case where, firstly, the interest-free loan affects the corporation's capacity to earn income and, furthermore, the interest-free loan is granted to a corporation by its sole shareholder or, if there are several shareholders, each shareholder has granted an interest-free loan to the corporation in proportion to the shareholder’s interest in the corporation. ... In this regard, the principles followed in … Canadian Helicopters … could be useful. ...