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CRA stated: Corporation B's activities are limited to the provision of services on behalf of others as a subcontractor and … the profits earned by Corporation B are not manufacturing and processing profits in Canada. …. However … it is possible that the subcontracting costs paid by Corporation A to Corporation B could be included in the "cost of manufacturing and processing labour" as defined in [Reg.] 5202 …. ...

A taxable capital gain from the disposition of a "Canadian resource property" is therefore not included pursuant to subparagraph 115(1)(a)(iii) …. [Furthermore] … it is highly doubtful that the Right can be considered real property …. Article 900 of the Civil Code of Québec, which states that "fruits and other products of the soil may be considered to be movables … when they are the object of an act of alienation,” leads us to believe that the Right would not constitute immovable property but rather movable property. ...

X commences to use his condominium exclusively for personal purposes, would he be able to use the s. 45(3) election to defer the taxation of the capital gain until the actual sale of his property if he designates the condominium as his principal residence – and would the answer change if Mr. ... However … where Mr. X … used the property entirely for the purpose of earning income and … at a later time began to use it exclusively for personal purposes … the taxpayer would be able to rely on the subsection 45(3) election if subsection 45(4) does not apply and the condominium becomes the taxpayer's "principal residence" …. ...

27 November 2012 External T.I. 2012-0445941E5 F- Action déterminée de petite entreprise-- summary under Qualifying Disposition Summary Under Tax Topics- Income Tax Act- Section 44.1- Subsection 44.1(1)- Qualifying Disposition shares issued to a family trust do not qualify as "eligible small business corporation shares" In finding that shares issued from treasury of a corporation to a family trust, which later were distributed to a capital beneficiary, did not qualify as “ eligible small business corporation shares” notwithstanding that, on their issuance, the corporation was an eligible small business corporation and the $50 million test was satisfied, CRA stated (TaxInterpretations translation): A qualifying disposition of an individual (other than a trust) means a disposition of shares of the capital stock of a corporation where each share disposed of meets certain conditions in the definition of "qualifying disposition" in subsection 44.1(1). ... In our view, the wording of the definitions of "qualifying disposition" and " eligible small business corporation share" in subsection 44.1(1) requires that the issuance of common shares be made to an individual who is eligible for purposes of a qualifying disposition. As a trust is excluded from the definition of "qualifying disposition", in our view, none of the shares described in your example could qualify as an “ eligible small business corporation share” as defined in subsection 44.1(1). ...

CRA responded: [S]ubsection 89(8) is technically applicable …. [R]esponsibility for tax policy … rests with the Department of Finance ….” ...

., CEE (or CDE) incurred in Year 2 could be renounced effective December 31 of Year 1 and $900 of CEE (or CDE) incurred in Year 3 could be renounced effective December 31 of Year 2, CRA went on to confirm its position in 9531266 that: [T]he exercise of a right to purchase a flow-through share triggers a new flow-through share agreement and … a new "agreement in writing" is not required …. As well … the period referred to in paragraphs (a) and (b) of the definition of "flow-through share" in subsection 66(15) begins on the date of exercise of the right to purchase a flow-through share and ends 24 months after the end of the month that includes that date, unless the original written agreement relating to flow-through shares and share purchase rights (the "original agreement") provides for a shorter period. ...

CRA noted that ATI is determined by the formula A + B – C, and A is determined by the formula D – E. with variable D in general terms referring to the taxpayer’s taxable income for the year determined without regard to s. 18.2(2). ...

A, CRA indicated that if Kieboom applied, " Mr. A would be considered to have disposed of a… right to dividends in Opco to Mrs. ...

The Directorate stated: [P]aragraph 13(34)(a) states … that where a taxpayer carries on a particular business, there is deemed to be a single goodwill in respect of the particular business. … [T]he goodwill and the customer relationship … constitute a single property, being the goodwill in respect of the Taxpayer’s business. … 2017-0709141C6 … confirmed that a designation pursuant to paragraph 111(4)(e) can be made with respect to internally generated goodwill. ...

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