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In finding that the resulting capital gain did not qualify pursuant to s. 110.6(2) as being in respect of the disposition of 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 ….” ...

EXPLOITEE ACTIVEMENT-- summary under Paragraph 79.1(6)(b) Summary Under Tax Topics- Income Tax Act- Section 79.1- Subsection 79.1(6)- Paragraph 79.1(6)(b) meaning of expenses incurred to protect creditor's rights What constitutes an “outlay or expense made or incurred … by the creditor at or before that time [of the seizure] to protect the creditor’s … right, in the particular property” for the purposes of s. 79.1(6)(b). ...

30 June 2003 External T.I. 2003-0182875 F- TRANSFERT DE POLICE D'ASSURANCE-- summary under Subsection 52(1) Summary Under Tax Topics- Income Tax Act- Section 52- Subsection 52(1) ACB bump on policy distribution to shareholder equal to s. 15 benefit in excess of ACB otherwise determined – even in absence of s. 52(1) CCRA indicated that where a permanent life insurance policy was distributed gratuitously by a private corporation to a shareholder, who was deemed under A of the ACB definition in s. 148(9) to have acquired the policy for its cash surrender value, and who was deemed to have an s. 15(1) inclusion equal to the policy’s FMV, the amount of the excess of the FMV of the policy over its ACB was to be added to the ACB of the policy to the shareholder – so that the policy’s ACB consequent on the transfer would should be equal to its FMV. ...

It then stated: In the case of a prescribed debt obligation described in paragraph 7000(1)(c) … i.e., in respect of which the greatest amount of interest payable in a year may be less than the greatest amount of interest payable in a subsequent year, the interest is calculated under paragraph 7000(2)(c) or (c.1) … as the case may be. ...

22 July 2003 External T.I. 2002-0175715 F- GAIN EN CAPITAL RESIDENCE PRINCIPALE-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence- Paragraph (e) Quebec agricultural lands controls would not have precluded the taxpayer from acquiring only ½ hectare for principal residence use A taxpayer purchased agricultural lands on which he constructed his principal residence and subsequently inherited an adjacent plot from his parents. ... CCRA found that the principal residence exemption would apply only to the first ½ hectare of land subsequently disposed of by him given that the Preservation Act controls would not have precluded him from having acquired and held the 1/2 hectare on a severed basis. ...

. … [W]e cannot conclude in the situation presented that the improvements meet the criteria for inclusion in Class 8 …. ...

Before computing her gain under ss. 128.1(4)(b), CRA noted that the cost of her interest was deemed to be nil by s. 107(1.1), and that the ACB of her interest was to be computed under s. 107(1)(a)(ii) and s. 108(1) – cost amount – para. ...

. … [T]he cost amount of the work-in-progress is nil to the SENC immediately before its distribution to the partners and therefore the cost of each partner's undivided interest in the work-in-progress is nil by virtue of the application of subparagraph 98(3)(b)(i). … When the corporation invoices the customers, the work in progress will therefore be taxed to the corporation. ...

28 June 2004 External T.I. 2004-0059311E5 F- Associated Corporations-- summary under Paragraph 256(3)(a) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(3)- Paragraph 256(3)(a) "controlled, directly or indirectly in any manner whatever" includes de jure control In response to questions regarding a debenture that was convertible into shares of the issuer (a Canadian-controlled private corporation) by the holder (Lenderco), with such conversion right having been “provided for in the debenture … to safeguard the creditor rights of Lenderco,” and the application of ss. 256(3)(a) and 256(6)(a), and before quoting HSC Research as support, CRA stated: [W]e do not share your view that the phrase "controlled, directly or indirectly in any manner whatever" cannot include de jure control. Rather, our position is that the phrase includes de jure and de facto control under subsection 256(5.1) …. ...

23 November 2004 External T.I. 2004-0094101E5 F- IT-474R Administrative Relief-- summary under Subsection 20(24) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(24) amalgamated corporation can make s. 20(24) election 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.” ...