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. … … Tinhorn Creek …concluded that winemaking was linked to viticulture and was an integral part of the taxpayer's farming business. ...

After two or three years of growth, the poplars will be harvested, chipped and burned in a biomass boiler to provide energy in the form of heat to various clients, In commenting on non-inclusion of the biomass boiler in Class 43.2, CRA stated: In the NRCan Guide, the term "wood waste" is defined … as follows: Main wastes and organic residues generated by activities directly associated with the forest industry and the manufacture of wood products, including: forest residues such as logging waste, unsaleable trees, salvage and deforestation residues and yard debris; sawdust, shavings, trimmings, cuttings and offcuts generated by the manufacture of wood products. mill wastes such as sawdust, bark, trimmings and offcuts;... ... Consequently, the biomass boiler related to thermal energy generation … could not be included in either Class 43.1 or 43.2. ...

. … [A] plan has a reasonable degree of risk if it allows the unused limit for a year to be carried forward for up to 12 months. … [A] plan does not involve a reasonable degree of risk where, for example, the employer can unilaterally revoke the plan, where the unused annual allocation can be refunded, or where the unused limit in one year and the unclaimed medical expenses in one year are both transferable to a later year. ...

. … With respect to the issue of the enforceability of a counter letter against a taxing authority, the Federal Court of Appeal held that, in its role as assessor, the taxing authority … must satisfy itself of the true legal relationship between the parties and assess accordingly. ...

28 April 2010 External T.I. 2010-0362101E5 F- Déductibilité des intérêts-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) under current use test, deductible interest increased to 100% when unit in triplex converted to rental use A three-unit rental property, whose purchase was financed with a mortgage loan (Loan #1), was used 46% (one of the three units) as the individual’s principal residence – but then on January 1, 2007, the individual purchased a new immovable that became his principal residence (the "residence" with the triplex then being used 100% for rentals. ... In order to complete the financing of his residence, the taxpayer obtained an additional loan (Loan # 2) secured by a mortgage on his residence. ...

CRA responded: Generally, compensation received by a former employee from the employee’s former employer for damages resulting from wrongful dismissal will be considered to be a retiring allowance …. ... However, where an individual has suffered personal injury before or after loss of employment (for example, if the employee was harassed while employed or defamed after being dismissed), it may be considered that the general damages received for that injury are unrelated to the loss of employment and, therefore, are not taxable. … In determining whether this is the case, the severance pay to which the employee would reasonably have been entitled is taken into account. ...

. … With respect to prizes awarded to owners of brokerage offices and their employees under draws held over a period of several months … these prizes will be required to be included in the income of the owners and employees receiving them pursuant to subsection 9(1) and paragraph 6(1)(a) respectively. ...

. … [U]se of a motor vehicle [is not] personal use if the employer requires the employee to travel directly from the employee’s home to a place other than the place of business where the employee regularly reports, or to return home from that place. … [T]he borough's public works office is a regular place of employment for the foremen. ...

Before indicating that this asset was not excluded under s. 233.3(1) – specified foreign property – para. ...

27 July 2010 External T.I. 2010-0364841E5 F- Questions relatives à une séparation-- summary under Supporting Person Summary Under Tax Topics- Income Tax Act- Section 63- Subsection 63(3)- Supporting Person no supporting person where two spouses lived separate and apart under same roof In connection with finding that child care expenses incurred in the year, in the context of the correspondent living separate and apart from the correspondent’s spouse but their living under the same roof with their children, will be deductible by the parent who paid the child care expenses, provided that all the conditions for claiming the deduction are satisfied, CRA stated: [T]here does not appear to be a "supporting person" … in the situation you have presented to us, since even if you lived in the same household as your spouse, you likely did not "reside with" her at any time during the first 60 days of 2010 …. ...