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In confirming that Canco is still required to issue T4s to them, and after referring to s. 153(1)(a) and Reg. 200(1), CCRA stated: [I]t is not necessary for the person paying the salary or wages be the employer of the taxpayer to whom the salary is paid (see, inter alia, Coopers & Lybrand …) or for the taxpayer to be taxable in Canada or resident in Canada. … [T]he amounts paid to the Employees appear to constitute salaries or wages within the meaning of subsection 248(1). ...

DSI of Holdco 2 after reorg: (DSI of Holdco 2 prior to reorg ($10) + $72 DSI considered to have been received from Opco per 2 above) x net cost amount of assets considered retained by Holdco 2 ($37 per 3 above, plus the $20 cost of other assets, totaling $57) / (net cost amount of assets of Holdco 2 “prior to” [sic] reorg ($57) + net cost amount of assets considered to have been received from Opco ($100 cost of Property 1)) = 82 x 57/157 = $30. 5. DSI of Holdco 2 considered to be transferred to Holdco 1: $82 – $30 = $52. 6. ... DSI of Holdco 1 after reorg: DSI of Holdco 1 prior to reorg ($1,000) + amount considered to have been received from Holdco 1 ($52) = $1,052. ...

CRA stated: [A]bsent novation of the debt … Canco's assignment of its debt receivable … would not constitute repayment of the debt by Debtco to Canco for the purposes of subsection 15(2.6). Since the debt would not be repaid as required under subsection 15(2.6), subsection 15(2) would continue to apply and the Part XIII tax imposed pursuant to paragraph 214(3)(a) would also remain. … If on the other hand, the debt was novated … section 245 may apply …. ...

2004 Ruling 2004-007680-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) // www.bci.ca/ "> www.bci.ca): Non-capital losses of BCI are transferred to its affiliate, Bell Canada, pursuant to transactions under which a subsidiary of Bell Canada ("Bell Subco") borrows up to $17 billion on a day-light loan and uses the borrowed money to subscribe for preferred shares of a newly-incorporated subsidiary of BCI ("BCI Subco"), BCI Subco lends the money on a non-interest bearing basis to BCI, BCI lends the same funds on an interest-bearing basis (1 basis point lower than the dividend rate on the preferred shares) to Bell Subco, which pays off the day-light loan. ...

. … [Here] … it appears that the move did not occur to enable the taxpayer to be employed at a new work location for purposes of the moving expense deduction. ...

A copy of the amended T4 slips for a given taxation year must be sent to the … CRA … and all affected employees informing them that they may request an adjustment to their income tax return for the particular taxation year. ...

In commenting on the meaning of “incurred,” CRA stated: … Wawang … stated: [T]he correct question to ask, in determining whether a legal obligation is contingent at a particular point in time, is whether the legal obligation has come into existence at that time, or whether no obligation will come into existence until the occurrence of an event that may not occur. ...

13 March 2012 External T.I. 2012-0433661E5 F- Notion de dépense engagée-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense expense not incurred if obligation therefor dependent on future contingency Before noting that “the concepts of ‘outlay or expense incurred’ under paragraph 18(1)(a) can apply to expenses incurred for the purposes of the medical expense tax credit,” CRA stated: … Wawang … stated: [T]he correct question to ask, in determining whether a legal obligation is contingent at a particular point in time, is whether the legal obligation has come into existence at that time, or whether no obligation will come into existence until the occurrence of an event that may not occur. ...

The Directorate responded: In light of paragraph 18 of the Bulletin [IT-518R] … and … Stapley, we are of the view that the use of the expression "enjoyment of entertainment" refers to the act of being entertained rather than to tangible property such as a book, musical instrument or Blu Ray disc player, the use of which could potentially provide a form of entertainment. ...

In such cases, and based on … Fries … those amounts will not be required to be included in the taxpayer's income since they do not represent income from a source in Canada. ...