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. … Between the parties, a counter letter prevails over an apparent contract. … Generally, the CRA agrees to recognize a counter-letter for tax purposes to the extent that: the counter letter is concluded before or at the same time as the apparent contract and does not constitute an ex post facto arrangement; the counter-letter is not a sham; the counter-letter is disclosed to the CRA and the relevant documents are sent to the CRA at the appropriate time (usually when filing the relevant tax returns); the facts relating to the particular situation corroborate the parties' legal relationships to the counter-letter. ...

. … Between the parties, a counter letter prevails over an apparent contract. … Generally, the CRA agrees to recognize a counter-letter for tax purposes to the extent that: the counter letter is concluded before or at the same time as the apparent contract and does not constitute an ex post facto arrangement; the counter-letter is not a sham; the counter-letter is disclosed to the CRA and the relevant documents are sent to the CRA at the appropriate time (usually when filing the relevant tax returns); the facts relating to the particular situation corroborate the parties' legal relationships to the counter-letter. ...

CRA stated: [R]equests for changes in fiscal periods … [must] be demonstrated to be prompted solely by sound business reasons other than obtaining tax benefits. ... Accordingly … it would seem unlikely that the Minister would concur with such a request. ...

. … [Accordingly] the sum received on the grant of an emphyteusis cannot be amortized over the term because the emphyteusis is not considered as a lease and the sum received is proceeds of disposition. However, by virtue of subsection 40(1) … a taxpayer can claim a reserve… 2012-047210 no longer reflects the CRA position…. ...

If this is the main use of the housing unit and if the … three criteria [in S1-F3-C2] are met, the housing unit could qualify in its entirety as a principal residence…. ….On the other hand, if the income producing activity is significant, structural changes have been made or CCA has been claimed for the property, only the part of the housing unit used for personal purposes by the son will qualify as a principal residence. …[T]he designation of the rental property leased to the son as a principal residence, in whole or in part, … will affect the calculation of such exemption upon the individual's disposition of his own principal residence. ...

The existence of separate entrances, separate heating systems, separate hot water tanks or a tax bill stating separate municipal addresses are other examples of factors that can also to [such] a conclusion …. ... Thus, if each unit can be normally be inhabited without access being provided to the other unit (for example, if each unit has a kitchen and a bathroom and they both have separate access), it would be difficult to regard the two units as a single housing unit …. ...

After noting that if the estate distribution occurred as part of the series in which Corporation A received its s. 84(3) dividend, the three brothers would have an increase in their interest in Corporation B described in s. 55(3)(a)(v), and with the estate distribution also constituting an s. 55(3)(a)(iii) event, CRA stated: [I]t appears … given … the jurisprudence on the concept of a series of transactions and on the interpretation of subsection 248(10), that the distribution of the shares of the capital stock of Corporation B could be part of a series of transactions in which the dividend was received by Corporation A. ...

This is relevant to … [s.] 55(3.1)(b)(ii), which applies to an acquisition of control of the transferor or transferee corporation … [but not] for the purposes of paragraph 55(3)(a) since subparagraphs 55(3)(a)(i) to (v) relate only to dispositions or increases in interest and do not apply to acquisitions of control. ...

. … The classification of the permits in this case must be made in accordance with their actual life established under the above criteria. Accordingly, it appears that the … permits acquired by the taxpayer represent eligible capital properties and not property which can be added to Class 14. ...

What about the Québec refundable tax credits could be considered as a "reimbursement" of medical expenses for purposes of paragraph 118.2(3)(b), in particular, the Tax Credit for Home-Support Services for Seniors ("CIMAD"), the Independent Living Tax Credit for Seniors ("CIALB") and the Rehabilitation Centre Tax Credit ("CISUT") – and may an individual who has treated a CIMAD as a medical expense for such purposes amend their tax returns for the last 10 years to adjust the calculation of the Medical Expenses Tax Credit ("METC")? ... These credits would not reduce the amount of eligible medical expenses for the METC. … [A]n individual who has already filed tax returns for the tax years 2013 and 2014 and treated a CIMAD as a medical expense reimbursement for purposes of paragraph 118.2(3)(b), may obtain, within the normal reassessment period, a correction for a tax return already filed for those years. ...