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If … the use of a computer and/or Internet service at home is not required as part of their job duties … [taking into account] the fact that the residual value of the computer after three years will be negligible … it would be reasonable to include in the employee's income one third of the value of the computer from which the portion equivalent to the employment-related use would be deducted. ...

11 May 2007 External T.I. 2006-0214351E5 F- Transfert d'un droit de propriété-- summary under Paragraph 40(2)(b) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(b) where duplex co-owned by husband and wife, the one unit occupied by them can be designated as a principal residence – but this changes when daughter moves into the 2nd unit A and his wife B, had been undivided owners of a duplex since 1999, and lived in one of the units with their daughter C, while the other was rented out. ... For each taxation year prior to 2004, only the housing unit ordinarily inhabited by A and B may be designated as the principal residence. … Similarly, we are of the view that C will be able to designate the housing unit into which she moved in 2004 as her principal residence for the years during which she ordinarily inhabited it …. ...

CRA stated: [U]nder paragraph 5907(11.2)(a) … if an FA is resident in a country with which Canada has a treaty but for the purposes of that treaty the FA is not considered to be resident of that country, it will be deemed not to be a resident of the designated treaty country for the purposes of section 5907 …. … As stated in paragraph 15 of Interpretation Bulletin IT-391R, a company is generally resident in the country in which its central management and control is exercised. ...

10 July 2006 External T.I. 2005-0153051E5 F- Somme forfaitaire- régime de pension agréé-- summary under Paragraph (b) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.2- Subsection 110.2(1)- Qualifying Amount- Paragraph (b) damages received regarding encroachments on pension plan surplus were not a qualifying amount Regarding the treatment of a lump sum received by the estate of a member of a defined benefit registered pension plan following the settlement of a class action suit against the employer, CRA stated: [T]he lump sum amount received by the trust in this case cannot be a "qualifying amount" … [as it was] received by the estate … not in respect of a series of periodic payments that should have been made in previous years but rather in respect of the surplus accumulated in the registered pension plan. … Note [also] that the term "specified portion" is defined as the portion of the qualifying amount that relates to the year, to the extent that the individual’s eligibility to receive the portion existed in the year. ...

. … [T]he fact that a government agency guarantees other aspects of the loan should not in itself prevent the taxpayer from deducting life insurance premiums that otherwise satisfy the other conditions for the application of paragraph 20(1)(e.2). … [P]remiums payable by virtue of a disability insurance policy required by the financial institution … are not covered by paragraph 20(1)(e.2) or any other provision of the Act and are not deductible in computing the taxpayer's business or property income. ...

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. … [A]lthough the item was won by chance by an employee, it was received by the employee in the course of the employee’s employment since only employees could participate in the draw. ...

The amount reimbursed to the taxpayer by the SAAQ, which his wife has certified as being receivable by her, is therefore to be included in computing the income of the person who rendered the services, i.e. the wife, as business income …. Where a victim receives the assistance amounts himself … and he freely choose to pay a family member instead of using the services of a third party, we are of the view that the amounts received by the service provider are taxable in service provider’s hands, even if the service provider is the victim's spouse, since those situations do not fall within the concept of support obligations raised in Maurice …., but rather reflect our general position. ...

. … [I]n the absence of [s. 74.5(3)(a)], the income from the rental property attributable to the period between April 15, 2004 and November 1, 2004 would have been attributed to Monsieur. ... [I]f there had been a resumption of their common life within the 90-day period, there would never have been a break down in the common-law partnership and the attribution rules would still have applied during the period in question (from April 15, to November 1, 2004). … [T]he income from the rental property attributable to the period after November 1, 2004 will … be attributed to Monsieur. ...

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. ...

As such … NRCo would be carrying on business in Canada. Under paragraph 150(1)(a) … a non-resident corporation that carries on business in Canada is required to file a T2 …. ...