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How might ss. 9(1), 15(1), 56(2), 56(4) and 18(1)(a) apply – and would this change if there were instead an agreement for royalties on a land sale? Before turning to the application of s. 56(2) (or, in some circumstances, s. 56(2)) to A, CRA stated: [T]he rent collections by Corporation A…would probably not have the "quality of income” to Corporation A since it would not be Corporation A which had an absolute and unconditional right to these amounts, as it was obligated to pay them over to A … [and] would not be included in Corporation A's income under subsection 9(1). ...

The Settlement Agreement stated that the Settlement Amount was paid to them “in consideration of the loss of entitlement to PRBs, the alleged violation of their Charter rights and discontinuing litigation … as general damages for future loss of PRBs...” ... CRA stated: Since the Settlement Amount is being paid to both current … and former employees, it is unlikely that the Settlement Amount would be a retiring allowance. ...

Therefore, to [that] extent … the amount would be included in employment income under subsection 5(1) or paragraph 6(1)(a) …. ...

The result … is double taxation for the partner of the partnership …. ...

21 August 2008 External T.I. 2008-0272241E5 F- Régime compl. d'assurance de soins médicaux-- summary under Subparagraph 6(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) a decrease in salary and increase in HCSA flex credits on renegotiation of employment contract does not result in an income inclusion Regarding employees who relinquish, once at the beginning of the year for their health care spending account, part of their salary increase in order to add additional credits, CRA stated: … IT-529 … states that if an employee forgoes an amount to which the employee is or will become entitled, such as a negotiated salary increase, vacation or bonus, the amount of remuneration forgone is included in income in the year in which the amount is converted to flex credits. ...

CRA responded that, generally, the commission from the sale of a life insurance policy of which that individual is the owner is not includible in the advisor's business income provided that the advisor is required to pay the premiums related to the policy (and similarly for a critical illness insurance policy) unless the amount of the commission is “substantial” – but that “commissions received by such a self-employed worker as a result of the sale of mutual funds or mortgage loans for which the individual is the owner must be included in his or her income from a business” – and similarly for the "joint" products described above. ...

. … [T]he settlement of the Debt for an amount less than its principal amount would trigger the application of section 80 if the Debt qualified as a "commercial debt obligation" and "commercial obligation". … [T]he Debt would qualify as a "commercial debt obligation" and "commercial obligation" if an amount in respect of interest on the Debt is deductible in computing Opco's income if such interest was paid or payable, or would have been had it been paid or payable, by the debtor in respect of it pursuant to a legal obligation. ...

After noting its position in IT-145R that “the execution of orders from bulk stock is not considered a processing activity where the activities involved consist solely of counting or measuring and repackaging” and the position in Tenneco that “the goods must undergo a change in form, appearance or nature” in order for there to be processing, CRA stated: [A]lthough the taxpayer's processing activities have the effect of making … [the] products more marketable, we do not believe that there has been any change in the form, appearance or other characteristics of the products. Therefore, the activities carried on by the taxpayer would not be eligible for the manufacturing and processing profits deduction … Words and Phrases processing ...

CRA responded: As noted in paragraph 4 of IT-226R, In the case of an equitable interest in a trust, the CRA considers a gift to have been made when the transfer of property …(… the shares of Realty Co) to the trust has been completed and the equitable interest in the trust has vested in the charity …. ...

. … Proposed paragraph 96(1.01)(a) does not require that partnership income or loss be calculated immediately after a member leaves the partnership. ... Proposed paragraph 96(1.01)(b) clarifies that the income or loss allocation for the final and/or partial period is included in the calculation of the ACB of the partnership interest under subparagraph 53(1)(e)(i). … Since adjustments to the ACB of a partnership interest related to the income allocation are normally made on the first day of the following fiscal period, this subparagraph mandates that the ACB be adjusted at the time the former member disposes of the interest. ...