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CRA stated: [A]ny amount paid to a retiree by Taxpayerco should be included in computing the retiree’s income under either section 5 or section 6 … [as] the payment … arises necessarily from the retiree’s employment with Taxpayerco. ...

In finding that the royalties were exempt under s. 212(1)(d)(vi), CRA stated: 9730076 and 2003-0018975 … no longer represent the position of the CRA. The practice of the CRA is to the effect that a royalty or similar payment respecting a copyright is not subject to any withholding tax under Part XIII …. ...

However … if the activities of a real estate or mortgage broker under the REBA … can be lawfully exercised through a corporation- which appears to be the case here- remuneration for the activities of the broker will be taxable in the hands of that corporation. ...

15 December 2010 External T.I. 2009-0349911E5 F- Calcul du PBR d'une participation dans une SEC-- summary under Subparagraph 53(1)(e)(i) Summary Under Tax Topics- Income Tax Act- Section 53- Subsection 53(1)- Paragraph 53(1)(e)- Subparagraph 53(1)(e)(i) no ACB bump for gains realized in the year until Day 1 of following year CRA affirmed its position as follows: … Income Tax Technical News No. 5 … states, in accordance with subparagraph 53(1)(e)(i), that in computing the adjusted cost base of a member's interest in a partnership at a particular time, only the income or loss of the partnership for fiscal periods already ended will be taken into account at that time. ...

11 February 2011 External T.I. 2010-0386651E5 F- Admissibilité- Frais médicaux-- summary under Paragraph 118.2(2)(a) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(a) preliminary report of genetic counsellor would not qualify In response to a query of the manager of a health care spending account as to whether an expenditure qualified under s. 118.2(2), CRA stated: [A]lthough … it is difficult … to comment on the application of [s. 118.2(2)(a)] with respect to costs related to a preliminary report of a genetic counsellor to establish the risk of breast cancer, we would generally be of the opinion that such costs are not incurred for maintaining health, preventing disease and diagnosing or treating an injury, illness or disability. ...

After stating that an “arrangement under which an employer reimburses its employees for the cost of medical or hospital care … fall[s] within the definition of PHSP … where the employer is required under the contract of employment to reimburse such expenses incurred by employees or their dependants,” CRA referred to the tests in ss. 118.2(2)(g) and (h) for the expenses to so qualify. ...

Although the transportation allowance in this situation is not strictly speaking a reimbursement of expenses … it is intended to compensate parents for an expense that would normally be borne by the … Board and not to generate income to them. ...

Without providing detailed analysis, CRA indicated that this asset was not excluded under s. 233.3(1) – specified foreign property – para. ...

The CRA summary stated: " Generally such activities will not be a source of income. " ...

CRA responded: Considering that the payments made … constitute royalties … they are therefore subject to paragraph 212(1)(d) without the need to refer to paragraph 212(1)(d)(i). ...