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After referencing the general principle that “interest expense on borrowed money used to make an interest-free loan … may be deductible … where the facts disclose that the money was borrowed for an indirect current use whose purpose was the earning of income from a business or property,” CRA stated: The CRA generally agrees that this is the case where, firstly, the interest-free loan affects the corporation's capacity to earn income and, furthermore, the interest-free loan is granted to a corporation by its sole shareholder or, if there are several shareholders, each shareholder has granted an interest-free loan to the corporation in proportion to the shareholder’s interest in the corporation. ... In this regard, the principles followed in … Canadian Helicopters … could be useful. ...

. … [However, where] individuals … live in a prescribed zone and maintain a self-contained domestic establishment for themselves or any other dependents in a non-prescribed zone … the absences of those individuals from the prescribed zone result in a break in the continuity of residence in the area. Thus, for those individuals … the principal place of residence is not in such a prescribed zone. ...

Regarding the federal treatment of the credit, CRA stated: The Quebec capital tax credit is an inducement payment and represents government assistance ….. It is not to be included in income under paragraph 12(1)(x) but rather is to be applied against the capital cost of the property that generated the credit under subsection 13(7.1) …. For the purposes of the investment tax credit, paragraph 127(11.1)(b) requires that the capital cost of the property that generated the credit also be reduced to take into account the government assistance. … These reductions must be recognized when the capital tax credit is received. ...

Regarding the federal treatment of the credit, CRA stated: The Quebec capital tax credit is an inducement payment and represents government assistance ….. It is not to be included in income under paragraph 12(1)(x) but rather is to be applied against the capital cost of the property that generated the credit under subsection 13(7.1) …. For the purposes of the investment tax credit, paragraph 127(11.1)(b) requires that the capital cost of the property that generated the credit also be reduced to take into account the government assistance. … These reductions must be recognized when the capital tax credit is received. ...

CRA stated: As indicated in … IT-213R, the amount or value of a prize received by a taxpayer from a lottery scheme is not taxable as either a capital gain or income unless … the prize can be considered, inter alia, to be income from employment. … CRA went on to find that “since only employees could participate in the draw … the employee who wins the item should include in the employee’s income the proportion of the value of the item that was paid for by a contribution made by the employer to the social club fund.” ...

7 February 2006 External T.I. 2005-0122381E5 F- Consequential assessment-- summary under Subsection 152(4.3) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4.3) taxpayer following a redetermination to allow a loss for Year 1 can carry that loss forward to a statute-barred year pursuant to s. 152(4.3) The Corporation initially had its loss denied for Year 1 but, many years later in Year 1 + X, CRA allowed that loss (“Determined Amount #2”). Can the Corporation carryforward the Year 1 loss (Determined Amount #2) to Year 1 + 2 (i.e., well prior to Year 1 + X)- even though the normal reassessment period for Year 1 + 2 has expired- in reliance on s. 152(4.3)? ...

X's property included in Class 14.1 in respect of the business was deemed to be $100,000 …. However, by virtue of paragraph 13(38)(c) … [t]he UCC balance for Class 14.1 in respect of Mr. X’s business... would be $75,000. … [The] agreed amount [of $100,000] would be deemed to be the proceeds of disposition of the property tor Mr. ...

CRA responded: If more than one property is donated at the same time … the amount of the advantage must be determined for each donation. ... In such a case, it is our view that the value of the advantage must be allocated on a reasonable basis among all of the donated property to determine the amount of the advantage in respect of each donation. … If a taxpayer has sold property to a charity and also donated other property to the charity … [and] the donations have enabled the taxpayer to sell the taxpayer’s other properties … the taxpayer may have received an advantage in respect of one or more gifts. ...

In finding that the Allowance might in fact be a reimbursement, in which case, it likely would be non-taxable, CRA stated: [E]ven if the employer uses the term "allowance" to refer to the payment made to an employee, it is possible that … the allowance may be a reimbursement of expenses. Consequently, if … the Allowance is, for example, based on an estimate of the travel and accommodation costs that the Employee will incur during the training period, or that Mr. A must show the Employer how the Allowance was spent, then it may be that the Allowance is more of an expense reimbursement and not a taxable allowance pursuant to paragraph 6(1)(b). … [G]iven that … the training appears to be primarily for the benefit of the Employer, the $15,500 Allowance may be non-taxable to Mr. ...

CRA stated: The guarantee … is provided by the Fund solely to enable Holdco to access the financial markets by issuing a short form prospectus in order to benefit from the expediency and other advantages stemming from that procedure. ... [P]rovided that all the conditions of section 253.1 … are met and that the Fund is not engaged in the business of lending money or guaranteeing loans …the requirements of subsection 132(6) … are not violated by the mere fact that the Fund provides the guarantee …. ...