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Given that such fees constitute business profits, the CRA would not grant a foreign tax credit for the 15% withholding tax on them …. ...

Consequently … subsection 115(2) will not apply as condition [s. 115(2)(c)](iii) is not satisfied. ...

. … CRA also indicated that FX gains or losses would be realized on a USD payable for the acquisition of shares as that payable was settled. ...

Furthermore … the amount of Holdco's GRIP is $400,000, since it seems reasonable to us to consider, in this situation, that the $400,000 dividend that Holdco received from Opco during 2001 is attributable to an amount described in Element A of the GRIP formula in respect of Opco. ...

Accordingly … only the taxable capital of the CCPC (Xco) should be considered for purposes of the proposed amendments to subsection 125(5.1) since the facts submitted indicate that the associated corporation (Yco) does not carry on business through a permanent establishment in Canada within the meaning of subsection 400(2) of the ITR. ...

Thus, where an organization issues a reimbursement for an eligible expense that was incurred in the previous taxation year … that reimbursement reduces the amount of the eligible expense and that a receipt must be issued accordingly for the year in which the expense was incurred. ...

Therefore … CanCo’s LRIP/GRIP balances (as applicable) would not be affected [and] subsection 214(16) would not alter the character of the income received by ForCo for FAPI purposes. ...

. … In addition, where a worker uses an automobile owned by the organization, not only for volunteer activities, but also for commuting to and from work, we are also of the view that this benefit does not give rise to tax consequences, provided that the cost of the automobile is reasonable and that it is the only personal use made of it. ...

Consequently … a non-resident may offset a taxable capital gain on the disposition of TCP (other than treaty-protected property) with a net capital loss on the deemed disposition of property that was not TCP that arose when the taxpayer was a resident of Canada. ...

CRA also provided a s. 55(2) ruling based on a representation that the only purpose “of the dividends on Newco’s Preferred Shares … is to provide a reasonable return….” ...