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In addition, where a user has been referred to a family-type resource or an intermediate resource by a "public institution" under [such] Act … part of the user’s contribution may also constitute such a benefit. This would be the case, for example, for any portion of a user's contribution that comes from the guaranteed income supplement or spouse's allowance paid in accordance with the Old Age Security Act or that comes from amounts of last-resort financial assistance paid under the [Quebec] Employment Assistance Program …. ...

CCRA responded: [T]o the extent that the Trust constitutes a testamentary trust … it will cease to exist only when all of its assets have been distributed to the beneficiaries. There is no provision in the Act regarding the duration of a testamentary trust. … [W]e refer you to Articles 1271 and 1272 of the CcQ, which provide for a maximum term of one hundred years for a personal trust such as the Trust. ...

12 December 2002 External T.I. 2001-0100755 F- Impact of LCB on Dr and Part IV-- summary under Subsection 129(2) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(2) general practice to net dividend refund against unpaid Part I tax Regarding the situation where a CCPC (Bco) was subject to Part I tax for a year but also to a dividend refund (DR), CCRA stated: Where a corporation is required to make a payment under the Act … the CCRA may, instead of paying the amount of the DR for the year, apply the amount of the DR for the year against that other obligation pursuant to subsection 129(2). … In general, the CCRA applies subsection 129(2) on an initial assessment, for example, when a corporation's tax for the year is still unpaid at the time of the initial assessment and the corporation is entitled to a DR for the year. ...

. … Pending completion of Finance Canada's analysis of this issue, the CRA will not require an employer to terminate a DSLP where one of the above conditions is not satisfied by an employee. This administrative position will apply regardless of the reason for the postponement of the leave or return to work. … ...

Notwithstanding our general view described above, we note that the CRA has previously applied … GAAR … in situations where mutual fund trust status was artificially achieved to facilitate abusive tax avoidance. ...

CRA stated: [A] payment made by an employer to a lessor to compensate for damages (including the total loss of a leased automobile) … would not be included in the standby charge calculation in subsection 6(2) …. ...

After indicating that such conversion would not cause a share disposition if no shares were cancelled and the rights of the shareholders were not substantively altered, CRA went on to indicate that if there otherwise was a disposition, s. 51 would not apply, stating: … 2013-0473771E5 … confirmed that a person who has a membership interest in a non-share capital corporation would not be considered to hold a share in that corporation. ...

11 March 2024 External T.I. 2022-0939331E5- Workers’ Compensation Settlement-- summary under Paragraph 56(1)(v) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(v) worker’s compensation received by an estate was includible in its income CRA noted that since s. 56(1)(v) required an income inclusion for "compensation received under an employees’ or workers’ compensation law … of a province in respect of an injury,” compensation received by the estate of an injured (and then deceased) worker pursuant to the Ontario Workplace Safety and Insurance Act was includible in its income (although there was a deduction in computing taxable income pursuant to s. 110(1)(f)(ii).) CRA stated: Once a particular payment is determined to be compensation received under an employees’ or workers’ compensation law of Canada, the fact that the taxpayer receiving the payment is employed, no longer employed, or deceased, is not a relevant factor …. ...

In a situation where an eligible individual dies during the month of March in a given year … the GST credit to which that person would otherwise have been entitled if that person had not died and which was paid in April must be returned to the Agency due to the application of paragraph 122.5(5)(c) …. ...

Accordingly, the annual amounts payable on January 1 of Year 2 through to January 1 of Year 6 are subject to the attainment of specified sales objectives of Bco for Bco's fiscal period ending on October 31 of the preceding year – but are subject to an adjustment on April 30 of the payable year. ... Response CRA stated (TaxInterpretations translation): … the CRA considers that an earnout feature in a sale agreement ends at the time the last contingent amount may become payable pursuant to the sale agreement. ... Accordingly, the annual amounts payable on January 1 of Years 2 and 3 are based on the sales of Bco – but are subject to an adjustment on April 30 of Year 2 or 3, as the case may be. ...