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If … the use of the property changed and it was subsequently used for personal purposes … this would constitute a change of use and the interest on the mortgages would cease to be deductible …. ...

25 September 2015 External T.I. 2015-0596921E5- Conversion from inventory to capital-- summary under Paragraph 45(1)(a) Summary Under Tax Topics- Income Tax Act- Section 45- Subsection 45(1)- Paragraph 45(1)(a) no 45(1) on conversion of house inventory to personal use Do the rules in s. 45(1) apply where a home builder, who initially held a property as inventory, commenced to use it for his personal use, having regard to " 2013-0493811C6, which discussed the CRA's views on C.A.E. ... The Queen, 2013 FCA 92 "? CRA responded: [In] 9335765… the CRA indicated that the rules in subsection 45(1) would not apply where real estate held by an individual as inventory is permanently converted to a capital property that is personal use property ("PUP")… [and] that the treatment of any gain on the ultimate sale of the particular PUP would not give rise to a gain or loss on income account. … [This] continues to represent the CRA's views. ...

25 September 2015 External T.I. 2015-0596921E5- Conversion from inventory to capital-- summary under Computation of Profit Summary Under Tax Topics- Income Tax Act- Section 9- Computation of Profit no s. 9 income when house converted to personal use is sold Do the rules in s. 45(1) apply where a home builder, who initially held a property as inventory, commenced to use it for his personal use, having regard to " 2013-0493811C6, which discussed the CRA's views on C.A.E. ... The Queen, 2013 FCA 92 "? CRA responded: [In] 9335765… the CRA indicated that the rules in subsection 45(1) would not apply where real estate held by an individual as inventory is permanently converted to a capital property that is personal use property ("PUP")… [and] that the treatment of any gain on the ultimate sale of the particular PUP would not give rise to a gain or loss on income account. … [This] continues to represent the CRA's views. ...

6 May 2011 External T.I. 2011-0399491E5 F- Withholding- stock option benefits-- summary under Subsection 153(1.1) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1.1) CRA may consider source deductions issue in rulings context Respecting the situation where the sole remuneration of an employee in 2011 was a stock option benefit, or the cash remuneration in the year was insufficient to cover that required source deductions, CRA stated: [F]ollowing the adoption of new subsection 153(1.31) … an employer can no longer relieve itself of its obligation to withhold and remit the amount of Deductions … simply because the amount deemed to be paid as a benefit under paragraph 7(1)(a) would be non-pecuniary, it was the only remuneration paid to that employee in a particular taxation year or the remuneration paid or other pecuniary benefits paid in the particular taxation year were insufficient to cover the amount of the Deductions. … However, we would be willing to consider any particular situation as part of a request for advance rulings. ...

CRA responded: Where the landlord receives a payment during the term of a lease with a bargain purchase option … the landlord must allocate a portion of that amount to the lease and another portion to the purchase option, where that option has a value. … [A] method of allocating a payment between the lease and the proceeds of disposition of the option that unduly defers the inclusion of the rent in the lessor's income will not give an accurate picture of profit. The CRA has not issued guidelines to determine the amount to be allocated to a bargain purchase option, and … does not intend to issue such guidelines. ...

CRA responded: In both of the situations … you would generally be able to deduct an amount as a capital gains deduction … as long as all the conditions and limitations in subsection 110.6(2.1) are satisfied. The fact that you dispose of the shares of the particular corporation to an individual with whom you do not deal at arm's length should generally not prevent you from deducting an amount under subsection 110.6(2.1). … [I]n both of these situations, subparagraph 84.1(2)(a.1)(ii) could apply for the purposes of section 84.1 to reduce the adjusted cost base of the shares acquired by your child. ...

CRA stated: If … the survivor's benefit received by the individual's estate is one of the components of the long-term disability insurance plan, it is likely that this benefit would qualify as a "death benefit" …. … A benefit received as a consequence of the death of a person qualifies as a death benefit if it can reasonably be regarded as being paid in recognition of services rendered by that person in connection with an office or employment. ...

. … According to paragraph 148(10)(d), a policyholder is deemed not to have disposed of or acquired an interest in a life insurance policy as a result only of the exercise of any provision of the policy. Generally, the … CRA … considers that the change of beneficiary, in and of itself, does not constitute an amendment that results in a disposition of the life insurance policy. ...

. … According to paragraph 148(10)(d), a policyholder is deemed not to have disposed of or acquired an interest in a life insurance policy as a result only of the exercise of any provision of the policy. Generally, the … CRA … considers that the change of beneficiary, in and of itself, does not constitute an amendment that results in a disposition of the life insurance policy. ...

. … IT-373R2 describes the steps to be followed in determining the main tax rules that apply in respect of a woodlot. … Paragraph 7 of IT-481 … states that "[i]f a taxpayer acquires land on which there is standing timber (for example, freehold timberlands), such property is a timber limit.” ...