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CRA responded: [S.] 256(6.1) … is the legislative response to … Parthenon Investments …. ...

After observing that “[p]rovincial income tax is not deductible … since … [it] is not an expense incurred for the purpose of gaining or producing income but rather is an expense incurred because income was earned,” CRA stated: Capital tax is not a tax that is calculated on the income of a business but rather a tax calculated on the paid-up capital of the corporation. ... The 1991Budget of the Department of Finance is consistent with this approach. … Interest on capital tax will be deductible if the capital tax is deductible by virtue of section 9. ...

. … According to paragraph 148(10)(d), a policyholder is deemed not to have disposed of or acquired an interest in a life insurance policy as a result only of the exercise of any provision of the policy. Generally, the … CRA … considers that the change of beneficiary, in and of itself, does not constitute an amendment that results in a disposition of the life insurance policy. ...

. … According to paragraph 148(10)(d), a policyholder is deemed not to have disposed of or acquired an interest in a life insurance policy as a result only of the exercise of any provision of the policy. Generally, the … CRA … considers that the change of beneficiary, in and of itself, does not constitute an amendment that results in a disposition of the life insurance policy. ...

See, for example … Diktakis …. As such, half-siblings would qualify as being connected by a blood relationship since they are individuals who have a common parent …. ...

In addition … the payment of premiums … would not result in a taxable employee benefit … or a taxable shareholder benefit … because the corporation is the recipient of the insurance benefits. ...

In finding (contrary to an earlier position) that their respective co-ownership interests could constitute qualified farm property, CRA stated: [T]he term "property" is defined very broadly in subsection 248(1) and … includes an undivided interest of a co-owner in an immovable. … Consequently … an undivided interest in an immovable is, for the purposes of the Act, included in the expression real or immovable property in subsection 110.6(1). ...

After noting that it could not respond definitively to the presented facts, CRA responded: As indicated in … IT-206R[, para. 2] the question of whether the carrying on of two or more simultaneous business operations by a taxpayer is the same business is dependent upon, among other things, the degree of interconnection, interlacing or interdependence existing between the business operations. The factors to be considered in making this determination are set out in … IT-206R[, para. 3]. … [T] he question of what is the principal business of a taxpayer that is a corporation within the meaning of subsection 1100(12) I.T.R. is a question of fact …. As stated in … IT-371[, para. 7], there are no established criteria. … [T]he following factors are among those that may be relevant: (a) the profits realized by each of the businesses; (b) the volume and the value of the gross sales or transactions of each business; (c) the value of the assets of each business; (d) the capital employed in each business; and (e) the time, attention and effort expended by the employees, agents or officers in each business. ...

. … [T]he discharge from bankruptcy is not retroactive to the time the individual was declared bankrupt but … is effective from the date the proposal is approved by the court. … Although section 128 does not recognize proposals filed under the BIA, the discharge from bankruptcy [in] 2005 does not invalidate the filing and assessment of pre- and post-bankruptcy tax returns made prior to the date of discharge. … [T]he individual was bankrupt in the 2003 … 2004 … and the 2005 taxation year[s]. ... Since the approval of the proposal by the Court and the discharge of the individual's bankruptcy does not amount to an unconditional discharge under paragraph 128(2)(g) … we do not believe that this paragraph deems the unused portion of his tuition tax credits to be nil. Consequently, the individual may carry forward the unused portion of his or her tuition tax credits at the end of the 2005 taxation year … to the 2006 taxation year pursuant to section 118.61. ...

. … [I]t is necessary to look for the presence of a certain number of supervisory indicators … including … mandatory presence at a workplace, more or less regular work assignment, imposition of rules of conduct or behaviour, requirement for progress reports and control of the quantity or quality of work performed. … [I]t would appear that the relationship between the medical residents and the health care facility is one of employer-employee. ...