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The Directorate responded: [T]he CRA … allows a taxpayer who owns two or more rental properties that are located in two or more locations other than the taxpayer's principal residence to deduct reasonable travel expenses incurred in collecting rents, supervising repairs, and managing the property. Generally, we consider that a taxpayer who owns a single rental property is not carrying on a business and, as a result, the taxpayer’s travel expenses are considered personal and therefore not deductible. … Benjamin … 54 DTC 357 … determined that travel expenses incurred by a taxpayer to attend to rental properties are personal expenses of the taxpayer. The CRA does, however, provide relief for a taxpayer's reasonable motor vehicle expenses incurred by the taxpayer to transport tools and materials to a rental property to perform all or part of the repair or maintenance work on the taxpayer’s rental property, provided that the property is located in the taxpayer's home area. … It should be noted that this policy does not provide relief for travel expenses to collect rents if the taxpayer has only one rental property and is not carrying on a business. ...

17 July 2007 External T.I. 2007-0220121E5 F- Lac artificiel- catégorie d'amortissement-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 6- Paragraph (e) artificial lake qualifies as a “water storage tank’ Before finding that the costs of creating an artificial lake to be used for a fishing resort should be included in Class 6, CRA noted: … Oriole Park Fairways … 56 DTC 537 … relied on the ordinary meaning of the words "water storage tank"- which includes “a pool or lake, or an artificial reservoir”- to conclude that ponds on a golf course should be capitalized in Class 6 Words and Phrases water storage tank ...

. … The election … is therefore not permitted …. Words and Phrases accountant ...

CRA stated: In the case of a corporation, some of whose activities are employee lease-out services, that is, that the employee's services are retained by that corporation but the employee's duties are performed, in whole or in part, for another organization …, it is necessary to determine whether the corporation is carrying on a separate business … because … the employment income of an Indian from each of the businesses of such a corporation is … a separate property for the purposes of … section 87 …. ... The place where the employee lives, the place of residence of the employer and the place where the duties of an employment are performed are usually important connecting factors …. Where the location from which the business is actually directed and administered is located on a reserve, the employer will generally be considered to reside on that reserve. … As we noted in Employee Leasing: Tax-Planning Arrangements Based on Section 87, the location of the employer on a reserve is not a connecting factor strong enough, on its own, to exempt the employment income from tax where an Indian is employed through an on-reserve employer but performs the duties of employment off-reserve. ...

. … In the absence of a complete description … we cannot determine whether a conjugal relationship … exits …. ...

In addition … the payment of premiums … would not result in a taxable employee benefit … or a taxable shareholder benefit … because the corporation is the recipient of the insurance benefits. ...

After noting that this structure appeared to be intended to maximize the small business deductions by the five managementcos, CRA stated: According … Hughes Homes … 98 DTC 1082 … taxpayers have the burden of demonstrating that the fundamental reasons for the existence of the corporations are not tax-related. … [I]t seems unlikely that the corporate structure was put in place by the Individuals for reasons other than tax: … an operating corporation is created and used for each of the projects involving a real business risk; the payment of management fees to the management corporations instead of the payment of dividends (if the Operator had paid dividends, the management corporations would have been specified investment business corporations); … 4 out of 5 of the individuals are related by blood. ...

James, 66 DTC 5241for the proposition that “a request for an adjustment to the computation of net income to create a non-capital loss or increase such loss by taking into account the business losses realized during the 1995, 1996 and 1997 taxation years would be acceptable even if a new notice of assessment cannot be issued for those years,” and then stated: Pursuant to subsection 122.5(3), the GSTC is an amount “deemed to have paid during the specified month on account of their tax payable under this Part for the taxation year …”. Under subsection 152(1), the Minister reviews the return of income, assesses the tax and determines “the amount of tax … deemed by subsection … 122.5(3) … to be paid on account of the taxpayer’s tax payable under this Part for the year.” ...

CRA stated: In the case of a corporation, some of whose activities are employee lease-out services, that is, that the employee's services are retained by that corporation but the employee's duties are performed, in whole or in part, for another organization …, it is necessary to determine whether the corporation is carrying on a separate business … because … the employment income of an Indian from each of the businesses of such a corporation is … a separate property for the purposes of … section 87 …. ...

30 January 2006 External T.I. 2005-0159331E5- Long term disability lump sum payments-- summary under Paragraph 6(1)(f) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) lump sum in lieu of future benefits under employee disability plan is non-taxable In response to a query as to CRA’s position regarding the taxability of lump sum payments of long-term disability benefits that do not represent arrears, it stated: On the basis of … Tsiaprailis … taxable amounts under paragraph 6(1)(f) … include lump sum settlements that are attributable to disability payments in arrears and accruing to the date of the settlement. However, where an individual receives a lump sum payment in lieu of future benefits that would have been otherwise paid under an employer long-term disability plan, in circumstances such that the payment can reasonably be considered to be proceeds of disposition of an interest in an insurance policy, it is our view that the proceeds are not taxable under paragraph 6(1)(f) of the Act or as a capital gain pursuant to subparagraph 39(1)(a)(iii) …. ...