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In keeping with the intent to consider a taxpayer’s gross income under paragraph (c) … only the amount of taxable capital gains (without any offsetting allowable capital losses for the year) should be included …. ...

In accordance with Abrahamson … the fact that the original source of funds in a foreign individual retirement plan was a pension plan is not relevant. ... Nevertheless, any income or capital gain earned in connection with such a plan is generally taxable in Canada on a current, annual basis …. ...

., that amount could not constitute an "excluded amount" by virtue of subparagraph (e)(ii) of the definition …. [I]t would not be possible to consider that an amount distributed by a corporation in a year subsequent to the disposal of the activities of the business is derived from that business for the year. … [S]ince the construction business was not carried on in the year in which the dividend was received by Mr. ...

X withdrew the minimum amount (as defined in subsection 146.3(1)) from his RRIF ($5,000 – so that a T4RIF slip is issued to him for $5,000), and effected the withdrawal through the transfer to his regular brokerage account at a licensed securities dealer of 100 common shares of a public corporation with a fair market value at the time of transfer of $5,000. ... CRA responded: [T]he meaning of "sale" is not exhaustively defined for the purposes of section 230 of the Regulations. … The transfer by an individual TFSA holder of securities to his or her TFSA as a contribution in a situation as described above is not a sale for the purposes of subsection 230(2) or subsection 230(6) of the Regulations, even if there is a disposition of the securities at their fair market value by the individual because of the application of paragraph 69(1)(b) and paragraph (c) of the definition of "disposition" in subsection 248(1). ...

CRA stated: [R]egarding the lump-sum and top-up supplement amounts, it does not appear that these amounts would constitute income from a source, including social assistance under paragraph 56(1)(u) … and therefore would not be included in income …. ...

8 April 2020 External T.I. 2016-0668991E5 F- Death of RRSP or RRIF annuitant-- summary under Subsection 146.3(6.2) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(6.2) s. 146.3(6.2) deduction can be less than the formula amount and does not depend on timely receipt of T4RIF – but applies only when the last annuitant of a RRIF dies Is the deduction provided under s. 146.3(6.2) discretionary when the surviving spouse is named sole beneficiary in an unmatured RRIF contract? ... CRA stated: [S]ubsection 146.3(6.2) … is not applicable in such a situation since no amount is otherwise deemed to be received by the deceased annuitant under subsection 146.3(6) and, in addition, the amounts paid to the Spouse under the RRIF will not be designated benefits, If the estate does not receive the T4RSP or T4RIF slip on behalf of the deceased annuitant within the prescribed time, can subsection 146(8.9) or 146.3(6.2) still apply? ...

. … CRA officials have discussed this concern with officials of the Department of Finance Canada who are presently considering several submissions on issues relating to the DSLP rules that have arisen due to COVID-19. …. ...

14 August 2020 External T.I. 2019-0829811E5- Crown Agent Status w/respect to Para. 149(1)(o.2)-- summary under Paragraph 4802(1)(e) Summary Under Tax Topics- Income Tax Regulations- Regulation 4802- Subsection 4802(1)- Paragraph 4802(1)(e) a provincial incorporating statute’s declaration of deemed property ownership by the provincial Crown was respected Aco, which is described in its enabling legislation as an agent of the provincial Crown and is stated in such legislation to hold all its property as the Crown’s property (the “Deemed Ownership Provision”) (and also is not described in Reg. 4802(1)(b), (c) or (d)) invests in a corporation (Invesco) described in s. 149(1)(o.2)(i), (ii), (ii.1) or (iii) whose shares currently are owned by persons described in s. 149(1)(o.2)(iv) – or, alternatively, a wholly-owned subsidiary (Holdco) acquires such shares. In finding that Aco qualified as a prescribed person described in Reg. 4802(1)(e), CRA stated: By virtue of the Deemed Ownership Provision … that deems the Crown to own all of Aco’s property, the Crown would be considered to own any shares of Invesco acquired by Aco. ...

. … [D]epending on the circumstances surrounding subsequently deposited amounts, these payments could possibly contravene the requirements under paragraph 60.011(1)(b) …. ...

CRA responded: In general … the mere presence of a capping policy such as the one at issue here is not sufficient to conclude that an allowance paid to an employee is deemed not to be reasonable by virtue of paragraph 6(1)(b)(x). … The situation described in your request is unique in that it presents the possibility that an employee may, for a portion of the total distance travelled in the performance of employment duties, receive no allowance. ...