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. … In Mr. A's case, it is reasonable to assume that the assumption of responsibility for the mortgage debt obligations was intended to generate income by protecting his investment. ...

. …. [N]otary fees are fees for legal services for the purposes of paragraph 62(3)(f). ...

. … However, the portion of such premiums that does not contribute to the increase of the cash surrender value of the Policy at that time will not be on hand at the safe income determination time and would therefore reduce the amount of safe income that could reasonably be considered to contribute, immediately before the Dividend-in-Kind, to the accrued capital gain on the Opco shares on which that dividend is received. ...

See summary under s. 125(7) – specified partnership income. No rulings are provided on ss. 85(2) and (3). ...

. … [T]his policy was not acquired with a view to earning income from the business. ...

. … [T]his policy was not acquired with a view to earning income from the business. ...

See summaries under s. 73(3) and s. 110.6(1) – qualified farm or fishing property. ...

. … [T]his approach should be preferred, in any situation similar to that described in Scenario 3, for establishing who has de jure control of a corporation. ...

. … [S]ince the necessity to effect the circular calculation…is well known, we believe that a reasonable and prudent person would have effected the circular calculation in order to report (in the income tax return filed) the correct figures to the Minister. ...

. … After paraphrasing the definitions of "resident contributor," "contributor" and "resident beneficiary" (which latter definition referenced a "connected contributor to the trust,") CRA stated: Under subsection 94(1), a "connected contributor" includes any contributor to the trust at a particular time other than a person all of whose contributions to the trust made at or before the particular time were made at a non-resident time of the person as defined in subsection 94(1). ...