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. … [S]ince the other direct or indirect shareholders of Holdco A are not related persons, and the transactions … include a sale of Holdco A shares as part of the same series as the deemed dividends … the application of subsection 55(2) is operating as intended. ...

CCRA noted that it was a question of fact whether her borrowing was for the purpose of earning income from property, that “it is the net loss or income determined under the Act that is … attributed” pursuant to s. 74.1(1), so that “the interest expense paid by Ms. A … will be taken into account in determining the loss or income to be attributed to her spouse … pursuant to subsection 74.1(1),” and that s. 245(1) might be determined to apply. ...

However, an annuity contract purchased by a taxpayer or the taxpayer's representative with a lump sum received as damages for personal injury will be considered an annuity contract … and will be a source of income to the taxpayer. Paragraphs 81(1)(g.1) and 81(1)(g.2), however, exempt a taxpayer's income from personal injury damages for taxation years in which the taxpayer was under the age of 21. … [T]he Agency's position with respect to structured settlements extends to allowing annuities that are subject to the provisions of the second paragraph of section 1616 of the CCQ but would otherwise qualify as structured settlements as described in IT-365R2, to be non-taxable where the minor creditor can elect to receive a lump sum within three months of attaining majority. The right of the minor to demand immediate payment of the present value of the balance of the annuity receivable within three months of attaining the age of majority is not in itself sufficient to refuse an application for an advance ruling on a structured settlement. … [T]he fact that the order is made by a court does not in itself prevent compliance with the requirements of IT-365R2. ...

. … [W]e would generally be prepared to consider this position in a situation where it is the parent corporation that gives the award to an employee of its subsidiary as long as it is not a means of exceeding the number of awards (and the $500 limit) provided for in the policy. … [C]ustoms duties and transportation costs, regardless of which corporation incurs them, must be added to the purchase price of the property to be given to the employee to determine if the gifts and awards policy applies …. ...

. … Holdco A should pay Part IV tax pursuant to paragraph 186(1)(a) on the dividend it received from Opco on November 30 … since at that time Opco was not connected with Holdco A. … [T[he fact that Opco was connected with Holdco A at any other time during Holdco A's taxation year would be irrelevant. ...

. … [T]hey are receiving an economic benefit from their employer. Furthermore … this reimbursement is not made in the context of a training program …. ...

. … [I]n Interpretation 1999-0011335 …[t]he transferee corporation was … considered to have been a member of the partnership immediately before the partnership ceased to exist even if it had been a member for only a fraction of a second. Thus, subsection 98(5) may apply in the situation you present where each of the partners transfers their interest in the partnership to Bco at a day’s interval since Bco is considered to have been a member of the partnership immediately before the partnership ceased to exist …. ...

CRA stated: … [T]he employer's contribution for all employees is 50% of the cost of the group disability plan while the other 50% of the contributions are borne by the employees. The fact that an employer arbitrarily allocates the contributions collected from employees so that they constitute 100% of the contributions paid to the long-term and short-term disability insurance plans does not make the disability insurance plan a fully employee-funded plan. … [T]he legal obligation to pay premiums is shared equally between the employer and the employees. Consequently, the benefits received by an employee from the long- and short-term disability plan are taxable in computing the employee's income pursuant to paragraph 6(1)(f) …. ...

23 November 2004 External T.I. 2004-0094101E5 F- IT-474R Administrative Relief-- summary under Paragraph 87(2)(a) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(a) IT-474R, para. 10 provides no administrative relief from short taxation year from amalgamation The taxpayer referenced the statement in IT-474R, para. 10 that “[w]here the provisions of paragraph 87(2)(a) produce unintended consequences … the Corporate Rulings Directorate … is prepared on a case by case basis to consider whether relief is appropriate,” and requested relief on the basis that the short taxation year (which had not been anticipated) resulting from an amalgamation produced an additional administrative burden. ... For example, we have previously allowed an amalgamated corporation to make the subsection 20(24) election, even though technically it could only be made by the predecessor corporation …. ...

CRA responded: [Under] the principle in … Poulin … an expense paid in a year in which a taxpayer is no longer carrying on business may be deducted in that year since the taxpayer cannot be considered to have ceased to carry on business as long as the taxpayer is engaged in following up on actions taken by the taxpayer in the course of carrying on business. … [P]remiums paid by a taxpayer to maintain liability insurance in respect of actions taken in the course of carrying on the taxpayer's business would be deductible in computing the taxpayer's income. ...