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. … … [T]he price adjustment clause … reduce[d] the redemption value of the Rollover Preferred Shares from $2,000,000 to $1,000,000…. [S]ubsection 191(4) would not apply … on the basis that no amount was actually and validly designated in respect of each of the Rollover Preferred Shares on the transfer of assets by Pubco to Subco, or on the basis that the amount originally designated in respect of each of those shares would exceed the fair market value of the assets transferred by Pubco to Subco. ...

. … [T]he CRA [will not] accept a late designation if it is for retroactive tax planning purposes, if the designation is part of a tax avoidance scheme, or if it is necessary, in order to give effect to the designation, to issue a … reassessment … [where] the normal reassessment period … has expired. ...

CRA responded: [S.] 256(6.1) … is the legislative response to … Parthenon Investments …. ...

CRA indicated that: “based on the context in which the RUTT regime was introduced … the definition of a RUTT should be interpreted broadly. ... The CRA Guidance stated that uncertainty is reflected in the financial statements, for example, if “the entity concluded it is not probable that the tax authority will accept an uncertain tax treatment and thus … it is probable that the entity will receive or pay amounts relating to the uncertain tax treatment ….” ... When that is the case, the RUTTs must be disclosed in Form RC3133 …. … [T]he notes to the audited financial statements prepared in accordance with … IFRS … or any other country-specific generally accepted accounting principles need to be considered when determining whether the uncertainty of tax treatments is reflected in the relevant financial statements …. ...

CRA responded: In … IT-99R5 … the CRA confirms that legal costs incurred to enforce pre-existing rights to interim or permanent support amounts are deductible. ... As a result of … Gallien v. The Queen … 2000 DTC 2514 … legal costs incurred to obtain spousal support pursuant to the Divorce Act, or under provincial legislation in the case of a separation agreement, are also deductible. However, in the case of common-law spouses, the legal costs incurred to negotiate either a … cohabitation contract or a separation agreement are for the establishment and negotiation of an entitlement to support. ...

CRA responded: [F]or the 2016 and subsequent years,... taxpayers who have failed to report the disposition of their principal residence [are required to] amend their income tax return …. For the sale of a residence in 2016, Schedule 3 … must be completed, on which must be stated the year of disposition of the property, its proceeds of disposition as well as its description. … Form T2091 … (or Form T1255 …), is required for the designation if the property was not the taxpayer's principal residence for all the years in which the taxpayer was the owner. For dispositions in 2017 and subsequent years … taxpayers will also be required to complete Form T2091 (IND) (or Form T1255). ...

1 May 2020 External T.I. 2020-0846931E5- CEWS- public institution-- summary under Paragraph 149(1)(d.3) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(d.3) functional approach to determining the ownership of the “capital” of a non-share corporation In response to an inquiry on the Crown corporation branch of the definition of a public institution in s. 125.7(1) of the CEWS rules, CRA first paraphrased the rules in ss. 149(1)(d) to (d.6) as well as referring to the deeming rule in s. 149(1.1), and then indicated that, in determining the ownership of the “capital” of a non-share corporation for these purposes, it would consider the following factors: • the identity of members, • the structure of the corporation, • who exercises control over the financing, operation and direction of the corporation, • who has the right to elect or change the board of directors or to reverse its decision, • who can contribute capital and receive a distribution of capital, • details regarding asset distribution on winding-up or dissolution and • whether a person other than her Majesty in right of Canada, a province or a Canadian municipality has any right to acquire any capital of the corporation. ...

Rather … this type of benefit is included in computing a taxpayer's income under paragraph 56(1)(a). Indeed … subparagraph 56(1)(a)(vii) … provides that a benefit paid under [such] Act … will be included in computing a taxpayer's income …. ...

Regarding whether this generated a taxable benefit under s. 6(1)(a), CCRA stated: [E]xpenses incurred by the employee to improve the employee’s housing unit that are not within the scope of those normally assumed or reimbursed by a landlord should not … reduce the value of the benefit …. However … where the expenses incurred by the employee are expenses that are normally borne by a landlord, the amount of this benefit could be reduced by a reasonable amount, which represents the disbursements made by the employee for work related to the employee’s housing unit that primarily benefits the employer/landlord. … Furthermore, we disagree that the value of the benefit computed for the purposes of paragraph 6(1)(a) should be reduced to take into account the time spent by the employee in carrying out the renovation work on the employee’s housing unit. ...

The Directorate noted that the relevant BC ITA provisions were modeled on ITA s. 125.4(1) – labour expenditure – (b)(iii) and s. 125.5(1) – Canadian labour expenditure- (b)(iii). In finding that this shareholding satisfied the above “belong to” test, rather than the shares belonging to the trust under the position of the TSO, the Directorate stated: [T]he shares … belong to [the individual] and not the Trust for purposes of the tax credit. ...