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". However, we would need to consider a specific situation … before making a final determination. ...

In finding that there was a benefit on the shareholder, CRA stated: [I]t … follows among other things from subsection 15(5) that subsection 15(1) can apply where a corporation makes property available to a person related to a shareholder. In the context of a private corporation … the CRA would presume prima facie that the sole shareholder is the directing mind of the corporation's operations. ...

12 September 2008 External T.I. 2008-0275041E5 F- Don de bien écosensible-- summary under Paragraph 110.1(1)(d) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.1- Subsection 110.1(1)- Paragraph 110.1(1)(d) donated ecologically sensitive land can be inventory In rejecting a submission that any property donated as an ecological gift is, by virtue of having been donated, a capital property, CRA stated: The definition of gifts of “ecologically sensitive land" described in paragraph 110.1(1)(d) … applies to property held as inventory or capital property. … The characterization of a particular property must be analyzed according to all relevant criteria. ...

6 October 2008 External T.I. 2008-0271421E5 F- Terres à bois-plan d'aménagement forestier Québec-- summary under Farming Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Farming woodlot, to be a farm, must focus on the fostering of the stand Before describing the requirements for a rollover under s. 73(3) (or 70(9), CRA noted the distinction in IT-373R2, para. 14 (approved in Desrosiers Estate) between a woodlot operation that was a farm (entailing “planting, nurturing and harvesting trees pursuant to a forestry management … plan and significant attention … paid to manage the growth, health, quality and composition of the stands”) and a logging operation, and that if the correspondent’s statement that “the land was used principally in a logging business” was correct, then the rollover would not be available. ...

8 November 2007 External T.I. 2006-0181621E5 F- Article 67.1- Frais de transport et de logement-- summary under Subsection 67.1(1) Summary Under Tax Topics- Income Tax Act- Section 67.1- Subsection 67.1(1) costs of transporting customers to an entertaining event and of their accommodation were “in respect of … entertainment” The taxpayer bears the expenses of inviting major customers to an event (described as an ”entertainment activity”), including meal expenses, tickets to attend events, transportation and accommodation expenses. CRA indicated that the transportation costs incurred by the taxpayer in order for the customers to travel to the event, and the accommodation costs of its customers during their stay, came within the scope of the limitation of amounts paid “in respect of … entertainment. ...

11 July 2006 External T.I. 2005-0152031E5 F- Actions admissibles de petite entreprise-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation building used 75% in the corporation’s active business operations and 25% for rental use would qualify A couple will transfer a co-owned building – that is used 75% in the operation of an active business of a corporation owned by one of them and 25% for rental to third parties – to the corporation on a rollover basis in consideration for shares with a FMV equaling that of the building. ...

11 October 2005 External T.I. 2005-0148281E5 F- Déductibilité de dépenses-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees accounting fees in preparing consolidated financial statements generally deductible In finding that accounting fees related to the preparation by a parent of consolidated financial statements for the group were generally deductible, CRA stated: … IT-99R5 … lists legal and accounting fees for a wide range of ordinary functions. ...

11 October 2005 External T.I. 2005-0148281E5 F- Déductibilité de dépenses-- summary under Subsection 248(24) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(24) s. 248(24) does not affect deductibility of fees for preparing consolidated financials In finding that accounting fees related to the preparation by a parent of consolidated financial statements for the group were generally deductible, CRA stated: … IT-99R5 … lists legal and accounting fees for a wide range of ordinary functions. ...

Whether a specific expense is a mandatory computer service fee is a question of fact …. In general … fees paid for services rendered by the computer department are allowable fees if they are mandatory fees. ...

In finding that the goodwill was not a qualified farm property, CCRA stated that “’farming’ … does not include the situation where an individual is limited to maintaining and caring for farm animals that the individual does not own and receives a fee for doing so. This is reflected, inter alia, in Juster ….” ...