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4 January 2022 External T.I. 2016-0644861E5 F- Travail de nature temporaire-- summary under Subparagraph 6(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) the "duties … of a temporary nature" condition is tested on a site-by-site basis After being asked how to apply the condition respecting "duties … of a temporary nature" in s. 6(6)(a)(i), in various contexts, including where an employee is assigned successively to two projects in the same region or city, or assigned successively to two separate projects at the same place of work, CRA referred to its positions on duties of a temporary nature in IT-91R4 and then stated: For the purposes of subsection 6(6), we are of the view that the place where an employee performs work of a temporary nature (i.e., a special work site) is a particular place of work and not a general geographical area such as a city. Consequently, it is generally from a special work site that all relevant facts of a project, or a particular phase of a project … must be examined in order to determine whether the work performed by an employee was of a temporary nature for the purposes of subparagraph 6(6)(a)(i). ...

" See summary under s. 248(1) – salary deferral arrangement – para. ...

6 April 1994 External T.I. 9331715- SAFE INCOME AND SRED EXPENDITURES-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) Current SR & ED expenses must be deducted in computing the corporation's safe income on hand even if such expenses have not yet been deducted for tax purposes. However, SR & ED capital expenditures do not reduce the corporation's safe income on hand until the year that such amounts are claimed as a deduction for tax purposes. ...

25 January 2002 External T.I. 2001-0114615 F- CONTRAT DE RENTE PRESCRITE ET FIDUCIE-- summary under Clause 304(1)(c)(iv)(B) Summary Under Tax Topics- Income Tax Regulations- Regulation 304- Subsection 304(1)- Paragraph 304(1)(c)- Subparagraph 304(1)(c)(iv)- Clause 304(1)(c)(iv)(B) requirement of fixed term where holder is a trust other than under s. 104(4)(a) In the course of a general discussion, CCRA stated: Clause 304(1)(c)(iv)(B) … has the effect of requiring that annuity payments be payable for a fixed term where the holder of the contract is a trust other than a trust described in paragraph 104(4)(a) …. ...

6 January 2003 External T.I. 2002-0173405 F- Capital Dividend Account-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(1)- Capital Dividend Account- Paragraph (a) application of transitional rules re changes in inclusion fraction including example CCRA provided an overview of the CDA computation in the context of the changes in the inclusion rates from ¾ to 2/3 to ½ (including the corporation receiving a capital gains distribution from a trust) and then dealt with a specific numerical example. ...

. … [If] moving from Residence B to Residence C was done to allow the taxpayer to occupy an employment … [and] assuming that the two relocations, from Residence A to Residence B, and Residence B to Residence C, are eligible relocations, the eligible relocation expenses for both relocations will be deductible in computing the taxpayer's income, provided all conditions in sections 62 and 67 are satisfied. … If it is established on the facts that the taxpayer did not ordinarily reside at Residence B before ordinarily residing at Residence C, we will consider that a single relocation from Residence A to Residence C has occurred, and that relocation took place in two stages. ...

. … In general, the work is considered temporary if it can reasonably be expected that it does not constitute a continuous employment of more than two years. However, this two-year limit is not automatically applied if the evidence demonstrates that the work done by an employee is of a temporary nature. … [A] taxpayer who accepts a new full-time, permanent job abroad, could not claim, at the time the job ended, that the taxpayer’s work was temporary in nature. … [Y]ou could only exclude the amount of expenses related to your housing for the period during which you performed your work at the New Workplace if the following requirements were met: while you were working at the New Workplace, you maintained elsewhere (in Canada in this case) a self-contained domestic establishment that was your principal place of residence; and the employment you had in the New Workplace was temporary in nature. ...

. … [B]y reason of the subsection 256(9) election, a deemed taxation year end occurs…at the time immediately before 18:00 hours….The corporation must take into account the taxation consequences of the sale transactions…and the share rollover …in the taxation year…which terminated immediately before the effective time of the acquisition of control. … Furthermore, given that the amalgamation occurs after all the transactions of January 18…including the acquisition of control…at 18:00 hours, the second taxation year of the corporation terminates immediately before the amalgamation by virtue of paragraph 87(2)(a). … The corporation would therefore technically have two taxation years that would be deemed to end during January 18, 20X1. ...

After noting that at the 1988 CTF Annual Conference, the Department stated that the safe “income was attributable to a particular class of shares of the capital stock of a corporation on the basis of the proportion of the profits of the corporation to which that class gave entitlement, if all the profits were distributed on a winding-up of the corporation,” CRA noted that, here, the USA established a preferential right of the Class A shares to a $5,000 dividend, thereby suggesting that the Class A shares would have an additional $5,000 profits entitlement on winding-up, and then stated: [T]he Class A common shares of the capital stock of Opco would give the right to a value of $10,333 ($5,000 + (($21,000- $5,000)/3)). ... Thus, the safe income on hand of the Class A common shares before the deemed dividend would be $5,905 ($12,000 × ($10,333/$21,000)) [and $905 after the $5,000 deemed dividend] and the safe income on hand attributable to the other two categories of shares would be $3,047 respectively ($12,000 × ($5,333/$21,000)). ...

In responding “no,” CRA stated: Where a taxpayer continues the taxpayer’s studies and receives scholarships or fellowships, the taxpayer will not be able to deduct the expenses incurred for the studies for which the scholarships were paid to the taxpayer … [whereas] paragraph 56(1)(o) permits a taxpayer to deduct expenses incurred in a taxation year for the purpose of continuing the taxpayer’s research. … If the principal purpose of the award is pursuing the recipient's education and training for the recipient (for example, if the recipient is studying for a PhD), the scholarship is included in accordance with subparagraph 56(1)(n)(i), even though research is being done to achieve that objective. ... Where such research allows the recipient to continue the recipient’s education and training, such a benefit does not negate the principal purpose of the grant provided that such benefit could be considered to be a secondary purpose of the grant or an inevitable but incidental benefit. … In your situation, the scholarships you receive seem to be scholarships or fellowships, not research grants, because …the research you are currently conducting is focused on obtaining a postgraduate degree. ...