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CRA responded: Innovative … [dealt with] a group creditor life insurance policy and not an individual life insurance policy. ...

George Thompson & Company, Limited (1927), 13 TC 83 (Eng. KB) (“Scales”) sets out the test for the determination of whether certain operations are a separate business. ...

Canadian Western Natural Gas, Light, Heat & Power Co. ((1922) 69 DLR 401 (Alta SC (AD)). ...

. … [E]xpenditures in respect of research in determining economic viability may be considered to be on income account …. ... [If] … the expenditure brings into existence an asset or advantage that has an enduring benefit... it is denied current deduction …. ...

Would this satisfy the condition in s. 146.01(1) – regular eligible amount- para. ... In responding negatively, CRA stated: [O]nly after the individual has actually contributed amounts to the individual’s RRSP, no later than the first 60 days of the year, and indicated the total amount contributed as an HBP repayment for the previous taxation year on the prescribed form … will the individual be able to declare that the individual’s HBP balance is nil at the beginning of the calendar year. … [W]hen the individual makes a withdrawal from the individual’s RRSP on January 20, 2022, his HBP balance at the beginning of the year 2022 for the purposes of the definition of "regular eligible amount" will [still] be $5,000 … because no HBP repayments have yet been made and reported on the prescribed form. ...

CRA responded: The definition of reimbursement is consistent with Verdun …, which states “Even when these amounts are…reasonable estimations of the costs…[they are] additional remuneration, not…reimbursement of expenses, which require detailed receipts….” In most cases, the best evidence to show how much was spent is the actual receipt (for example, an invoice). … c. ... CRA responded: Paragraph 2.26 will be revised to better reflect Spence … [where t]he FCA… noted that “costs of the benefit to the employer is the wrong instrument to assess the value of the benefit. …” ...

[T]he [above] treatment … which allows income in the executor’s year to be considered as payable to the beneficiaries (if all of the beneficiaries agree to the treatment) relates only to situations where the estate has not been wound up in the executor’s year such that the estate administration continues beyond the first year. ... Where the income is distributed or made payable to the beneficiaries pursuant to the terms of the Will, the amount must be included in the beneficiaries’ income, unless a valid subsection 104(13.1) or (13.2) designation is made …. ... Further … [such] guidance would also apply where the end of the estate’s tax year coincides with end of the executor’s year ….” ...

7 October 2011 Roundtable, 2011-0412161C6 F- Timing of the increase in interest- stock option-- summary under Subparagraph 55(3)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(3)- Paragraph 55(3)(a)- Subparagraph 55(3)(a)(ii) grant of in-the-money options to key employee as part of same series could be a significant increase in interest – which otherwise occurs on exercise Mr. ... Instead it references the holding of an economic interest in the corporation. … A stock option often has conditions that make the exercise of the option uncertain and contingent. ... However … an increase in an interest in the corporation occurs when the stock option is granted rather than when the option is exercised … in a situation such as that described, where a key employee, instead of an immediate receipt of shares in the corporation, receives a stock option with characteristics and price such that there is no real uncertainty or contingency as to the exercise of the stock option. ...

Regarding Q.3.1, CRA stated: Taxpayer and Purchaser Corporation would not be deemed by paragraph 84.1(2)(e) … to be dealing at arm’s length. ... Regarding Q.3.2, CRA stated: Taxpayer and Purchaser Corporation would not be deemed by paragraph 84.1(2)(e) … to be dealing at arm’s length. However, Taxpayer would be deemed, for the purposes of section 84.1 …, to have disposed of the Subject Shares to the person who acquired them from Purchaser Corporation (himself). … [W]e are prepared to apply this provision such that, if Taxpayer had disposed of the Subject Shares directly to the subsequent purchaser and section 84.1 … would not have applied to that disposition, the First Disposition will not be subject to section 84.1 …. ...

Under Article 948 of the Civil Code of Québec … [a]n owner of an immovable (for example, a piece of land) is the owner by accession to all structures and works located on the immovable. This position also applies to the term "property" used in the definition of "interest in a family farm or family fishing partnership" under subsection 110.6(1). … [W]ith respect to the determination of whether or not property was used principally [over 50%] in the carrying on of a farming business … IT-373R2 [para. 18] states: …Whether or not particular assets are "used principally in the business of farming" is a question of fact to be determined on a property by property basis …. ...