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CRA responded: We have assumed … that in the above described situation, the furnishings provided in the rental units consists of furnishings typically or usually found in a residence. In such case … the entire amount of the rental payments can be considered to be “rent from real or immovable properties” …. ...

CRA responded: The Act does not define "land" except for the purposes of subsection 18(2), where subsection 18(3) defines "land" to specifically exclude buildings and other structures …. ... Thus … for the purposes of subsection 70(5.2) … "land" includes not only vacant land, but also land on which other real property such as houses or condos are erected. ...

It stated: To the extent that Aco exercises its purchase option … Aco's cost of the Vehicle pursuant to subsection 49(3) will be the sum … paid in accordance with the exercise price … plus the adjusted cost base of the option, which will be the portion of the consideration paid that is attributable to the acquisition of that option. ...

In finding that the partnership would not satisfy various requirements of IT-426R, para. 2 for use of the cost-recovery method, including the requirement of subpara. 2(f) that “[t]he vendor is... resident in Canada”- CRA stated: The definition of “Canadian resident partnership” … is not relevant for the application of [subpara. 2(f)] …. Moreover, a limited partnership is not a person resident in Canada for the purposes of the Act (although it is deemed to be a separate person resident in Canada for limited purposes in subsection 96(1)) …. ...

. … [T]he original eligible dividend paid by Canco and received by a shareholder may be reduced by an elected amount up to the EEDD in respect of the dividend. ... Therefore, in scenario#1, Canco can reduce the $30,000 original eligible dividend paid on the Class A shares by a maximum of $10,000 by electing on the full amount of the EEDD in respect of that dividend. … It is not possible to elect on the full amount of the $30,000 eligible dividend paid to the Class A shareholder under subsection 185.1(2) to reduce the eligible dividend amount to nil. … The fact that two of the eligible dividends paid in scenario #2 are deemed taxable dividends resulting from share redemptions, pursuant to subsection 84(3), does not change the answer above. CRA has published the prescribed manner …. While the election must be made in respect of each EEDD on each eligible dividend, these elections can be combined into one letter to your tax centre…. ...

A) in respect of the specified individual (Spouse A) is actively engaged on a regular basis in the activities of the corporation (PC1) that is related to earning income from business …. ... A) in respect of the specified individual (Spouse A) owns, generally speaking, at least 10% of the fair market value of the corporation (PC1) …. As such, if it can be determined that the dividends paid by PC1 are “derived directly or indirectly” from a related business, which is likely given that the capital invested in the Portfolio was wholly-derived from either after-tax earnings of PC1’s medical services business or reinvested investment income, the “related business” exception would not be available …. ...

Turning to the particular question, CRA stated: [W]e would consider a student to have followed two different programs if the required number of hours on courses or work in a particular program (e.g., an undergraduate program) were to change from one semester / term to the next. For example, if an individual is normally enrolled as a FT student in a four-year undergraduate degree program, yet changes their enrollment to PT in a single term to only enrol in a three-week study-abroad program (other than a co-op placement / internship) during a particular month (whether in the summer or otherwise), we are likely to consider the student to have followed both a QEP and a SEP. ... Therefore, if the student in this scenario were to receive a … grant to cover the duration of the study-abroad program, the scholarship exemption would be calculated on the basis that the student was a PT qualifying student in the particular month. ...

. … That being so, para. 2.59 of the Folio [provides] … that there is no deemed disposition [if]: a) the income-producing use is ancillary to the main use of the property as a residence; b) there is no structural change to the property; and c) no CCA is claimed on the property. In your situation, it is not clear that … the income-producing use is ancillary to the main use of the property as a residence. ...

., the non-resident) …. Therefore re-appropriation under subsection 221.2(1) in respect of the amount would be available to Debtco, not Canco, and only to the extent that Debtco were to have an amount that is or may become payable for the purposes of the subsection. … [T]here is no situation where re-appropriation under section 221.2 is available when the re-appropriation would result in the refund of an amount contrary to legislated time limits (such as in subsections 227(6) or (6.1) and section 164). In addition, there are currently no provisions of the Act or the Income Tax Regulations which divest the payor (e.g., Canco) of their obligations under section 215 …. ...

Expenses incurred related to the adoption of a child from Country A are not eligible …. As for Scenario 2, the expenses incurred for the adoption of a child from Country 1 could qualify as eligible adoption expenses … provided that these steps lead to adoption of a child for whom the expenses were incurred …. ...