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. … 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. ...

. … [I]t is the obligation to pay the contribution that determines who is responsible for funding a plan. … IT-428 [para. 17] states that the Canada Revenue Agency will not accept a retroactive change to the tax status of a plan. ...

. … [W]here a franchisor and a franchisee are at arm's length … the shares of the franchisor held by a franchisee could be considered to be used in the business operated by the franchisee, to the extent that the subscription is a condition of membership under the banner, and the shares are pledged as security to the franchisor to secure the obligations of the franchisee. ...

In confirming that this worked as a technical matter, but before noting the GAAR could be engaged, CRA stated: If it were determined that the gain or loss realized by Aco in respect of Options #1 and #2 was on capital account, we would be of the view that subsection 49(1) would apply in this case to the sale by Aco of Options #1 in the particular taxation year and that, in accordance with our position in paragraph 29 of … IT-479R … the cost to Aco of acquiring Options #2 at the beginning of the taxation year following the particular taxation year would be a capital loss incurred at that time. ...

After noting that the final regulations under s. 871(m) imposed withholding on payments under certain notional principal contracts, derivatives and other equity-linked instruments that referenced dividends on U.S. equity securities, CRA stated: In our view, for the purposes of Canadian income tax reporting, in particular [Regs.] 201(1) and (2) … the characterization of payments received by a taxpayer should be based on the legal nature of the contract under which the payment is made, irrespective of the tax treatment in a foreign jurisdiction …. ...

29 May 2006 External T.I. 2005-0131701E5 F- Durée de l'exercice d'une société-- summary under Subsection 249.1(3) Summary Under Tax Topics- Income Tax Act- Section 249.1- Subsection 249.1(3) s. 249(3) did not preclude a 53 week fiscal period covering 3 calendar years Regarding a corporation's fiscal period that began on December 29, 1996 and ended on January 3, 1998, CRA stated: [T]he corporation's fiscal period can run from December 29, 1996 to January 3, 1998- a period not exceeding 53 weeks- and … the subsequent fiscal period of the corporation's business or property begins on January 4, 1998. … [S]ubsection 249(3) does not affect the length of the fiscal period of a corporation's business or property. ...

CRA quoted from the statement in Baker that: Defining "full-time employment" to be equivalent to the standard number of hours worked in an industry and area where the activities take place … is inconsistent with the scheme which is to ensure that a certain minimum level of activity exists in a corporation prior to allowing it the small business deduction. ... CRA then stated: In our view, a 30-hour or even 35-hour work week does not constitute full-time employment …. ...

11 July 2006 External T.I. 2005-0152031E5 F- Actions admissibles de petite entreprise-- summary under Paragraph 110.6(7)(b) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(7)- Paragraph 110.6(7)(b) transfer of property to corporation for a s. 85 agreed amount less than FMV of the property and the shares issued therefor does not engage s. 110.6(7)(b) A couple will transfer a co-owned immovable – that is used 75% in the operation of an active business of a corporation owned by one of them and 25% for rental to third parties – to the corporation on a rollover basis in consideration for shares with a FMV equaling that of the immovable. ...

In your situation, it would be possible to compute a capital gain equal to the difference between the FMV of the principal residence at the time of the transfer … and the FMV of the property at the time of the transfer by your father …. ...

CRA indicated that it considered the following statement in IT-352R2, para. 1 was consistent with Longtin: “Subject to certification by the employer … subparagraphs 8(1)(i)(ii) and (iii) allow a taxpayer, in computing income for a taxation year from an office or employment, to deduct amounts paid in the year as expenses for office rent, supplies and salary to an assistant or substitute. These expenses are deductible provided the following requirements are met: (a) the taxpayer is required by the contract of employment to pay for such office rent or salary, or to provide and pay for such supplies; [...] ...