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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. ...

. … [T]he mere fact that a Condo Owner sells only a Parking Space to another condo owner does not automatically preclude the Parking Space, which is a component of the housing unit, from qualifying. … [T]he "principal residence" designation relates to the Unit. ...

27 June 2016 External T.I. 2016-0637341E5 F- Partnerships- Negative ACB-- summary under Subparagraph 53(1)(e)(iv) Summary Under Tax Topics- Income Tax Act- Section 53- Subsection 53(1)- Paragraph 53(1)(e)- Subparagraph 53(1)(e)(iv) assumption of loan can be contribution, but not retained profits Rather than making current distributions of its cash flow to a limited partner, those sums are lent by the LP to the limited partner – then at the beginning of the following year the LP effects a distribution of the applicable share of the previous year’s profits to the limited partner by issuing a demand note to it and pays that note by way of set-off against the loans owing by the limited partner. After finding that the loans might have given rise to an immediate gain under s. 40(3.1), CRA went on to state: [T]he profits of a limited partnership in a situation such as that described would not be considered as contributions of capital for the purposes of subsection 40(3.13). … The concept of a contribution of capital to a general partnership (SENC) or limited partnership is not limited to what is mentioned in…your letter. ...

. … Typically, farm quota is a statutory licence to produce a quantity of regulated agricultural product. ... …[W]here units of a particular type of farm quota are indistinguishable from one another, the ECE, for the purposes of new subparagraph 13(37)(b)(ii), may be determined by averaging the total cost of the particular type of quota by the number of units of that type held. … [A]ssuming they are identical properties, for the purposes of determining the adjusted cost base of farm quota that is depreciable property included in new CCA Class 14.1, the averaging rule in subsection 47(1) would apply. ...

CRA responded: [E]ven though quotas are generally considered fungible assets that are difficult to identify in a partial sale … within this set of fungible goods, it is possible to have separate groups with their own tax characteristics. … [I]t is possible to structure the transaction so that, in the first place, the quotas eligible for the capital gains deduction can be identified and transferred with a utilization of the election under subsection 14(1.01) and, second, all non-qualified quotas are transferred free of tax under subsection 85(2). ...

CRA responded: [E]ven though quotas are generally considered fungible assets that are difficult to identify in a partial sale … within this set of fungible goods, it is possible to have separate groups with their own tax characteristics. … [I]t is possible to structure the transaction so that, in the first place, the quotas eligible for the capital gains deduction can be identified and transferred with a utilization of the election under subsection 14(1.01) and, second, all non-qualified quotas are transferred free of tax under subsection 85(2). ...

After noting the requirement in s. 73(1.01)(c)(ii) that “after the transfer, no other person, other than the settlor of the trust, may receive or otherwise obtain the use of any of the income or capital of the trust,” CRA stated: [T]he trust … could not qualify as an alter ego trust without age requirement since that trust would have several beneficiaries. ... The transfer of the shares of Mr X would be for the benefit of persons other than himself and that would contravene the requirement stipulated … above. ...

CRA responded:... 2001-0099055 … confirmed that two spouses may create a joint trust for the spouse or common-law partner and contribute property to the extent that the requirements of subsection 73(1), 73 (1.01) and 73 (1.02) are met. Thus, a transfer of ownership by one or both of the spouses to the trust would be eligible for the rollover under subsection 73(1). … [O]nly Mr. ...

After noting its position in ITTN No. 40 that “a travel allowance paid by the employer in respect of travel within the municipality or metropolitan area of an employee for the purpose of the performance of the duties of the employee’s office or employment may be excluded from income if … the allowance is reasonable [and] is paid primarily for the benefit of the employer,” CRA stated: [A]n allowance would be paid primarily for the benefit of the employer if the principal objective of the allowance is to ensure that the employee's duties are undertaken in a more efficient manner during the course of a work shift, and where allowances paid are not indicative of an alternate form of remuneration. In such a case, we are generally of the view that the allowance of $17 paid for the days during which the employees are travelling should not be included …. ...

Where … an amount on which an income tax is payable under Part XIII was paid to an agent for or on behalf of the non-resident person who is entitled to payment without the tax having been deducted or withheld, subsection 215(3) provides that it is then the responsibility of the agent to deduct or withhold the Part XIII tax payable in respect of the amount received on behalf of the non-resident. Since the requirements imposed by subsection 214(1) remain applicable in such a case, it follows that the amount from which the agent is required to withhold 25% is the gross amount of the rents collected by the agent for or on behalf of the non-resident. … In order for only the amounts actually paid to the Owner to be subject to the 25% withholding, the Manager and the Owner must make an election under subsection 216(4). ...