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X's capital cost ($200,000) and the amount by which that cost exceeded the proceeds of disposition ($50,000) would be deemed to be CCA deducted in preceding taxation years, whereas “the capital cost to the corporation of the building for the purposes of all other provisions of the Act would, in accordance with our position in paragraph 10(a) of … IT-217R … be considered to be Mr. ...

. … [W]here the transaction is not commercially reasonable, the borrowed money does not meet the test in paragraph 20(1)(c) of being used for the purpose of earning income. [T]he fact that Profitco's income is "foreign accrual property income" … will not, in and of itself, change the Agency's position. ...

14 September 1996 External T.I. 9629825- PHSP CVRGE FOR SAME SEX LIFE PRTNER OF AN EMPLOYEE SECTION 6(1)(a)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Following the HRC decision in Moore & Akerstrom, RC has determined that a plan which provides coverage for same sex couples can meet the definition of a "private health services plan". ...

., exclusive possession of the property was not given), CRA cited Will-Kare for the proposition that " the concepts of a sale or a lease have settled legal definitions. ...

21 September 2011 External T.I. 2010-0375361E5 F- Liquidation d'une coopérative agricole-- summary under Subsection 84(2) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(2) s. 84(2) applied to winding-up of cooperative Respecting the treatment of the winding up of an agricultural cooperative within the meaning of s. 135.1(1) pursuant to which the cooperative distributes the balance of its assets to its members (with such distribution not satisfying the definition of " allocation in proportion to patronage” in s. 135(4). ...

Regarding the consequences of disposing of the bond between the November 1 due dates, CCRA stated: IT-410R [para. 3] … states that interest accrued between two due dates for the payment of interest on the obligation will be calculated at the rate stipulated in the terms of the obligation. ...

Canadian Acme Screw & Gear, Ltd. [1971] S.C.R. 628. ...

Canadian Western and Natural Gas, Light, Heat & Power Co. in concluding that the word "similar" meant "of the same general nature or character", and went on to indicate that in the past it had regarded the following properties or services to be similar: (a) system software and applications software; (b) trucking of sand and gravel, and trucking of poultry and lumber; (c) mining and sale of metallurgical coal, and mining and sale of other minerals; (d) operating a hotel which includes a restaurant and lounge, and operating a restaurant and lounge; (e) operating a hotel or motel with no restaurant, operating a restaurant, and operating a hotel or motel with a beverage room but no separate restaurant, and operating a hotel with a restaurant; (f) operating a prime rib restaurant and operating a steak restaurant even where the latter is operated in conjunction with a hotel; (g) the sale of fast-food chicken and the sale of fast-food fish; (h) staging musical concerts in a stadium, and staging professional football; (i) security equipment, and electro-magnetic labels developed for use in libraries, hospitals and retail establishments; and (j) the manufacture of parts and major components for aircraft, and the design, manufacture and sale of aircraft. ...

18 December 2000 External T.I. 2000-0050255- CHANGE IN TERMS OF DEBT OBLIGATION-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition disposition if implied rescission due to fundamental change going to root of contract In response to a general question as to " whether a change in the terms of a debt obligation would result in a disposition of the existing obligation and the substitution of a new obligation in its place," CRA stated: "If, in accordance with the relevant contract law in Quebec, the changes in the terms of the original debt obligation have resulted in a novation (where the original debt obligation is discharged and substituted by a new obligation), it is appropriate to view the original obligation as having been disposed of for income tax purposes. ...

. … IT-169 … addresses situations where the CRA determines that the FMV is higher or lower than the price otherwise determined by the parties to an agreement. Consequently … this Bulletin does not apply in this situation. [I]t is impossible … to comment as to its retroactive effect to the day of the initial transaction, since we do not have all the particulars …. [I]f it were appropriate to retroactively adjust the sale price, the CRA could apply subsection 152(4.2) in respect of taxation years already assessed … [but the] taxpayer must satisfy the five conditions for the CRA to agree to a reassessment giving rise to a refund. ...