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. … [T[o the extent that the expenses incurred are reasonable in the circumstances … the cost of testing for the bacterium could be a deductible expense in computing a taxpayer's income under paragraph 18(1)(a). ...

In finding that the individual thereby realized a s. 7 taxable benefit that was computed in the usual manner notwithstanding that a portion of that benefit had accrued prior to his immigration, CRA noted that s. 7 benefits were excluded under s. 128.1(1)(b)(iv) and s. 128.1(10) – excluded right or interest – (c). ...

. … [I]f an entity adopts ASPE, the term retained earnings for the purposes of paragraph 181.2(3)(a) will be defined in accordance with ASPE. … [T]he adjustment to the retained earnings of the corporation as a result of the revaluation of its assets will be taken into account for the purposes of paragraph 181.2(3)(a) to the extent that the presentation of such adjustment conforms with ASPE. ...

However, when the payment of the balance of such leave is made annually in accordance with an employment agreement … this payment is not in recognition of long service when the payment is made upon the employee's departure … [and] is usually considered employment income ...

14 April 2009 External T.I. 2009-0307791E5 F- Allocation de retraite et congé de maladie-- summary under Retiring Allowance Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance payout of accumulated sick leave on employment termination can be a retiring allowance – but not where it has been annually distributed Pursuant to the collective agreement, an employer grants sick leave to its employees annually, with the balance of the sick leave paid out in December of each year, except that if there is a termination of employment during the year, the balance is paid out at that time. CRA noted (citing Harel) that “the payment of a lump sum to cover the balance of unused sick leave accumulated over the years can be considered a retirement allowance” – but, here, the sick leave payouts likely were employment income given that “the payment of the balance of such leave is made annually in accordance with an employment agreement.” ...

[T]he fact that your client has earned more than $20,000 as of October 2009 … [indicates] that there is a source of income …. ...

14 April 2009 External T.I. 2007-0238221E5 F- Rights of musician-Transfer-- summary under Subsection 56(4) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(4) s. 56(4) generally will apply where royalty is transferred without assignment of copyright, with exception of SOCAN royalty As part of a general response respecting the transfer of rights by a musician to a corporation, CRA stated: [I]n … F 2002-0149781R3, the CRA took the position that subsection 56(4) would apply to the transfer to a corporation by an individual of royalty entitlements arising from contracts with a publisher, on the basis that the related copyright, no longer held by the individual, was not also transferred to the particular corporation. ... That said, the CRA took the position in … F 2002-0149781R3 to not apply subsection 56(4) to the transfer of royalty rights under an agreement with the Society of Composers, Authors and Music Publishers of Canada (formerly the Society of Composers, Authors and Publishers of Canada Limited and hereinafter "SOCAN") in light of the particulars of such agreement. ...

. … This trust will be eligible for the deduction under paragraph 104(6)(b) only to the extent that it has amounts of income that have become payable to a beneficiary. … Subsection 150(3) specifies that every agent or other person administering, managing, winding up, controlling or otherwise dealing with the property, business, estate or income of a person who has not filed a return for a taxation year shall file a return in prescribed form of that person’s income for that year. ...

.” … In this case … only interest at the legal rate and the additional compensation provided for in the Civil Code of Quebec accrued since the date of the judgments of the Superior Court of Quebec must be included in the calculation of the plaintiffs' income under paragraph 12(1)(c). ...

4 March 2010 External T.I. 2009-0348411E5 F- Bâtiment non-résidentiel admissible-- summary under Subsection 1101(5b.1) Summary Under Tax Topics- Income Tax Regulations- Regulation 1101- Subsection 1101(5b.1) separate classes and separate letter elections for separate additions to the same non-eligible non-residential building After indicating that a second addition made in 2009 to a building (the “main building”) that was not an eligible non-residential building under Reg. 1102(4) could be included in a separate class from a first addition made in 2008 to the main building, CRA stated: Consequently … a taxpayer must make the election under subsection 1101(5b.1) of the Regulations for each eligible non-residential building for which the taxpayer wishes to claim the additional CCA under subsection 1101(1)(a.2) of the Regulations. … [T]herefore, the 2009 addition will be classified in a separate class from the 2008 addition. ...