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. … Premiums paid by the corporation for the rider to the policy allowing it to obtain a premium refund amount if the shareholder does not have one of the covered illnesses or medical conditions after 10 years are not deductible on the basis of the application of paragraphs 18(1)(a) and 18(1)(h). ...

For example … negotiating a collective agreement would not include the duties of ensuring its application and representing the union's employee members in a grievance. ...

Before concluding that “the new corporation did not carry on a business at the time the shares were issued” so that “those shares were not shares of an eligible small business corporation,” CRA noted that there was no evidence that “a software development activity … [had] started at the time the taxpayer invested in the corporation,” and also stated: [T]here may be arguments that the business was started at the time that steps to change the zoning were taken. ...

Beaudoin … 2004 DTC 2414, held that the payment of funds from an RRSP to pay a debt extinguished by the order of discharge of a bankrupt does not constitute the receipt of a benefit by the bankrupt within the meaning of subsection 146(8), since the bankrupt does not receive any money or benefit as a result of that payment. ...

In indicating that a portion of the sums distributed appeared to be taxable under s. 6(1)(j), with the balance being proceeds of disposition of memberships (having a nominal adjusted cost base), the Directorate stated: [T]here are good arguments to state that the amount received … by each of the members, up to the amount of their union dues paid in XXXXXXXXXX, constitutes a refund of their annual dues that reduces or cancels the deduction provided for in subparagraph 8(1)(i)(iv) in computing their employment income. ...

. … [We cannot] conclude that they are regular ministers because they are not authorized to perform most or all of the functions of a minister, including administering most of the sacraments of the Roman Catholic Church. ...

11 January 2005 Internal T.I. 2004-0104341I7- Reclassify CDE of partnership to CEE-- summary under Subsection 66.1(9) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(9) "... paragraph (f) of the definition of CDE (which allocates the partner's share of CDE incurred by the partnership) does not contain any wording which changes the character of the expenses from the original character, i.e., the original character being expenses referred to in paragraphs (a) to (e) of the definition of CDE. ...

. … [T]he Canadian citizen to whom you refer in your request will be able to benefit from the exemption for the gain realized on the disposition of the residence located in France to the extent that a person with French nationality whose situation in fact and in law is identical to the individual’s own could benefit from it. ...

After paraphrasing the s. 20(1)(r) wording, indicating that, to be deductible, “the contributions must relate to services rendered to that corporation as an employee” and discussing the s. 67 limitation, CRA stated: [T]hat subsection does not … restrict the contributions necessary to fund an RCA. ...

A, who held ½ of the common shares of Opco having a PUC and ACB of $100, a safe income on hand of $699,900 and a fair market value of $1,000,000, transferred his common shares to a new corporation (“Holdco”) in consideration for common shares of Holdco, with the s. 85(1) agreed amount being $300,000, thereby realizing a $299,900 capital gain for which he claimed the capital gains deduction. ...