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Indeed, under paragraph 1102(1)(c) … depreciation is deductible only if the property was acquired for the purpose of gaining or producing income. ...

28 April 2011 Internal T.I. 2011-0394301I7 F- Obligation de l'employeur- feuillet T4 modifié-- summary under Subsection 152(4.2) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4.2) procedure for employee to request correction of incorrectly reported T4 benefit When asked what an employer should do when it discovers that T4 slips issued by it incorrectly showed an automobile benefit, CRA stated: [S]ubsection 152(4.2) … covers, in particular, situations in which an employee, who has received T4 slips that have been amended for previous taxation years, requests the CRA to correct the income tax return already filed for those taxation years. ...

. … Where a person is both a shareholder and an employee of a corporation and receives a benefit from that corporation, the Canada Revenue Agency generally considers that there is a presumption that the person benefited from that benefit as a shareholder where that person exercises significant influence over the conduct of the affairs of the corporation. ...

22 February 2012 External T.I. 2011-0421671E5 F- Loss of retirement income benefit- death-- summary under Subparagraph 110(1)(f)(ii) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110- Subsection 110(1)- Paragraph 110(1)(f)- Subparagraph 110(1)(f)(ii) deduction for WSIB compensation paid to estate of deceased injured worker An injured worker was entitled to receive monthly payments from the Ontario Workplace Safety and Insurance Board ("WSIB") until 65, with a lump sum paid to the worker at 65 as compensation for the loss of the monthly payments – or to the worker’s survivors if he did not attain that age. ...

After describing the application of s. 70(5.1) to the original bequest, and noting that its policy on price adjustment clauses did not apply in this situation, CRA stated: [I]f it were appropriate to retroactively adjust the sale price, the CRA could apply subsection 152(4.2) in respect of taxation years already assessed … [but the] taxpayer must satisfy the five conditions for the CRA to agree to a reassessment giving rise to a refund. ...

. … [G]iven that the property would be the patrimony of an inter vivos trust, the transfer of the shares of a joint spousal or common-law partner trust will contaminate a future testamentary trust to be put in place on the death of Mr X or Ms X. ...

The Directorate first quoted a statement in 2005-0158871E5 that: [A] "representation allowance" in the context of subparagraph 6(1)(b)(iii) … is an allowance paid to a worker having to work outside the country and is intended to lessen the inconveniences arising out of having to move abroad, being subject to different living conditions and, where applicable, having to face a higher cost of living. ...

It then started leasing the property to a non-associated corporation – and then disposed of the property, thereby realizing recapture of depreciation. ...

We continue to believe that the term "person … connected with a shareholder of a particular corporation" as provided in subsection 15(2.1) may include a partnership. ...

In the course of a general discussion, CRA stated: Subsection 227(6.1) … provides for repayment of Part XIII tax paid on a loan deemed to be a dividend by virtue of paragraph 214(3)(a) if the borrower, in whose name the tax was paid, repays the loan after December 21, 1992 and the repayment was not made as part of a series of loans or other transactions and repayments. ...