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Thus, a partner receiving undivided interests in shares held by a partnership in accordance with subsection 98(3) could be considered to hold shares of the corporation for the purpose of determining whether the recipient is entitled to the capital gains deduction …. … [T]he shareholder has held the undivided interests in the shares for more than 24 months and will continue to hold them until their disposition. ...

22 June 2005 External T.I. 2005-0136941E5 F- Don par testament-- summary under Subsection 152(4.2) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4.2) the terminal return could be requested after the normal reassessment period to be reassessed to reflect a gift under the will Regarding charitable gifts made in cash under the will of the deceased after the expiration of the normal reassessment period for the taxation year of the deceased’s death to qualifying entities, CRA stated: [P]aragraph 152(4.2)(a) … applies in situations where the taxpayer is an individual, other than a trust, or a testamentary trust, and the application is for the determination of a refund to which the taxpayer was entitled or the reduction of an amount payable by the taxpayer for the particular taxation year under Part I …. ...

2 November 2005 External T.I. 2004-0093601E5 F- Fiducie au profit d'un mineur-- summary under Paragraph 104(18)(d) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(18)- Paragraph 104(18)(d) there can be discretion to delay payment, but not as to the share CRA repeated its statements at 1998 APFF, Q.27 (9M18520) that: [S]ubsection 104(18) … does not stipulate any requirement as to the date of handing over or payment of the income accumulated in the trust. The condition set out in paragraph 104(18)(d) of the Act states that the right to part of the amount is not subject to any future condition, other than a condition that the individual survive to an age not exceeding 40 years. … [T]his paragraph would not be met if the beneficiary’s vested right to part of the amount could be extinguished by reason of a future condition other than the condition of surviving to an age not exceeding 40 years. ...

20 September 2005 External T.I. 2005-0140601E5 F- Ristournes- Coop de travailleurs actionnaire-- summary under Subsection 135(1) Summary Under Tax Topics- Income Tax Act- Section 135- Subsection 135(1) s. 135(1) can apply to payments to worker members of a shareholder worker co-operative CRA indicated that a shareholder worker co-operative can make payments to its members that will be deductible under s. 135(1), stating: In F 2001-0091015, we … noted that the term "customer" for the purposes of section 135 includes a member to whom the worker cooperative renders services by providing work directly or indirectly. We then concluded that a patronage dividend that is calculated on the basis of the amount of work done directly or indirectly by that member for the co-operative would be a deductible amount under subsection 135(1) since it would satisfy the definition of "allocations in proportion to patronage". … In the case of a payment made pursuant to an allocation in proportion to patronage, we are of the view that the amount of such a payment received by a worker who is a member of a shareholder worker co-operative will be included in computing the worker's income under subsection 135(7) for the taxation year in which the payment was received. ...

. … [I]t would appear that your travel expenses were incurred to monitor and manage the situation arising from the death of your tenant and not to earn income from the property. In addition, because of the clear prohibition in paragraph 18(1)(h) … you cannot deduct in computing your rental income the meal and living expenses that you incurred while staying in Longueuil, as those are personal and living expenses. ...

X acquired an income interest in a testamentary trust, and the children acquired a capital interest, CRA stated: The fact that there are two different civic numbers … is an indication that there are two housing units. However, other elements may also come into play, such as separate entrances, separate heating systems, separate hot water tanks, a tax account with two civic addresses, etc. … [W]e have assumed that the Immovable had two separate housing units. ...

CRA stated: Under subsection 102(1) … NRCo would be required to withhold Canadian income tax from the remuneration that it pays to the employee that is reasonably attributable to the employment duties performed by the employee in Canada. … NRCo would not be required to deduct employment insurance premiums if the employee remains a resident of his home country and pays into an unemployment insurance plan there. ...

CRA responded: Due to the expression “except such portion that is deductible by the EPSP under subsection 20(11) of the Act … as it appears in paragraph 144(8.1)(b) … an employee beneficiary of an EPSP is, effectively, restricted to a foreign tax credit of no more than 15% of the foreign non-business income (other than income from real or immovable property) allocated to them by the EPSP. ...

. … Paragraph 87(2)(a) indicates that … Amalco will be a new corporation and will not be a member of the Partnership immediately before the Partnership has ceased to exist. ...

The athlete’s employment income … is $1.2 million, of which 40% is allocable to Canada. Accordingly, $480,000 is included in the athlete’s taxable income earned in Canada …. ...