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Regarding the meaning of the “or” italicized above, CRA stated: A strict reading of subparagraph 55(5)(e)(i) indicates that either the dividend payer or the dividend recipient has to be a corporation (herein referred to as “such corporation”) the shares of which are qualified small business corporation shares or shares of the capital stock of a family farm or fishing corporation, and not both …. ... However a textual, contextual and purposive interpretation of subparagraph 55(5)(e)(i) does not allow us to override its wording …. ...

In finding that the partnership would not satisfy various requirements of IT-426R, para. 2 for use of the cost-recovery method, including the requirement of subpara. 2(f) that “[t]he vendor is... resident in Canada”- CRA stated: The definition of “Canadian resident partnership” … is not relevant for the application of [subpara. 2(f)] …. ...

If the 2019 Interest was unpaid on December 31, 2020, the exception in subsection 15(2.6) would not apply …. ... A would then be required to include the amount of the 2019 Interest in his income for 2019 … regardless of whether the Loan was also included in Mr. ...

. … While the phrase "incurred a debt" could, if applicable, include accrued interest, it is the CRA's view that accrued interest such as 2019 Interest in the Particular Situation does not meet the meaning of "debt" in the context of a textual, contextual and purposive interpretation of subsection 80.4(2). … [S]ubsection 80.4(2) would not apply for the 2019 year to the 2019 Interest paid on December 15, 2020, whether or not the Loan is repaid before the Corporation's 2020 year-end. ...

. … [F]or [these] purposes … the period of active farming or fishing by one or more eligible persons (i.e., the taxpayer, the taxpayer’s spouse (or common-law partner), a child of the taxpayer, or a parent of the taxpayer), does not have to coincide with the period of ownership [of the particular property by the taxpayer. ...

. … Consequently … SENC could elect, under subsection 1103(1), to include in Class 1 of Schedule II, the properties in Classes 8 and 10, but could not include those covered by the election under subsection 1101(5b.1). ...

. … Consequently … SENC could elect, under subsection 1103(1), to include in Class 1 of Schedule II, the properties in Classes 8 and 10, but could not include those covered by the election under subsection 1101(5b.1). ...

Regarding whether the minivans were “automobiles”, CRA stated that “a minivan is generally an ‘automobile’ … even if it has been adapted by an employer to be used to transport equipment, unless one of the exceptions provided for in subparagraphs (e)(i) and (ii) of that definition applies” and that, regarding such exceptions, “a minivan is generally a vehicle of a type similar to a van-type vehicle because of its resemblance to a van, both in its design and in its use.” Regarding the exception in (e)(i), it stated: [A] minivan that originally had more than three seats could still be considered to have a maximum of three seats … for the purposes of subparagraph (e)(i) of the definition of "automobile" in subsection 248(1) if the modification reducing the number of seats to a maximum of three seats is of a permanent nature. ...

CRA indicated that in the absence of any apparent “legislation that authorizes the practice of reiki in any of the Canadian jurisdiction … reiki practitioners are not considered to be medical practitioners under paragraph 118.4(2)(a),” so that amounts paid to them are ineligible. Regarding the possibility of Reiki treatments being performed by members of a health profession, CRA noted that it understood that the College of Massage Therapists of Ontario (CMTO) seems to allow registered massage therapists (RMTs) to integrate “First Degree Reiki” into massage therapy treatment plans, in which case, their services would still be considered to be registered massage therapy, with the associated fees being eligible for the METC – whereas RMTs choosing to offer “Second Degree Reiki” or reiki, in general, as a stand-alone “complementary modality” were not permitted to describe such services as registered massage therapy, so that the amounts paid for such reiki treatment would be ineligible. ...

. … [M]aterial salvaged from each of the activities outlined above could be captured by the definition of “wood waste” … provided that it is waste and that it has maintained its physical and chemical properties of wood. ...