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. … [A] plan will not be a pension plan where the only payment provided for under the terms of the plan is a single lump sum payable on retirement or loss of employment. … [A] plan that is excluded from being a salary deferral arrangement (“SDA”) by virtue of the special exception for professional athletes in paragraph (j) of the SDA definition in subsection 248(1) [also] will not be a pension plan, regardless of the form of benefits provided. ...

Consequently, in such a case, the costs associated with renting office space or premises would not be required to be included …. Furthermore, where a partner or owner of a business that is a profession contributes to the work in progress, the amount representing this contribution is not to be included in the cost of such work. … ...

CRA responded: The making of the section 34 election is not excluded by paragraph 96(1)(d) …. ... Should Partnerco become a member of the Partnership on January 1, 2018 …paragraph 34(b) would apply … [so that] Partnerco, as a member of the Partnership, would therefore be subject to an election made in the previous taxation year by the Partnership. ...

CRA confirmed its position that: [W]here a person’s worldwide income is subject to a particular Contracting State’s full taxing jurisdiction but that Contracting State’s domestic law does not levy tax on the person’s taxable income … we will generally accept that the person is a resident of that Contracting State unless the arrangement is abusive … [e.g., it] is placed within the taxing jurisdiction of the particular Contracting State in order to gain treaty benefits in a manner that does not create any material economic nexus to that Contracting State…. ...

Consequently … the cost incurred by the Taxpayer for shares of the capital stock of SIVAC … is deemed, by virtue of paragraph 85(3)(f), to be equal to the ACB of the Taxpayer’s interest in the LP immediately before the winding-up of LP. ...

However, in order to meet the test in clause 95(2)(a)(i)(B) … it would … be necessary to establish that if the funds on which the interest was earned had been held by Manco, such funds would be employed or at risk in the business of Manco (i.e. not excess funds). ...

. … Where a debt obligation is transferred between scheduled interest payment dates … [p]aragraph 20(14)(a) will have the effect of adding to the transferor's income, for the year of the transfer, any interest accrued at the time of the disposition that was not included in computing the transferor's income and that is not payable until after the time of the transfer. ...

.$50,000 from his share of partnership income before selling his ½ interest for Cdn.$275,000. ... However, the step-up under s. 48(3) did not apply for CCA/recapture purposes, so that on the disposition he realized recapture of depreciation based on proceeds equal to this capital cost of ($175,000 + $50,000, or) $225,000. ...

In finding that such exchange likely would be viewed as one between persons not dealing at arm’s length so that s. 84.1 likely would limit the PUC of the shares received on the above exchange, CCRA stated: [T]he parties … could be acting together in a highly interdependent manner with no separate interest, particularly in relation to the share transfer described [above]. Furthermore, it seems … that Opco would have no distinct interest in acquiring shares of Holdco I, Holdco II and Holdco III, other than to accommodate its ultimate shareholders, namely Mr. ...

In finding that such exchange likely would be viewed as one between persons not dealing at arm’s length so that s. 84.1 likely would limit the PUC of the shares received on the above exchange, CCRA stated: [T]he parties … could be acting together in a highly interdependent manner with no separate interest … [and] Opco would have no distinct interest in acquiring shares of Holdco I, Holdco II and Holdco III, other than to accommodate its ultimate shareholders, namely Mr. ...