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. … [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. ...

., film companies) – and would the answer change if it did so through a wholly-owned taxable subsidiary? ... In contrast, “the anticipated profits from renting out the Co-op’s common areas to third parties … [were expected] to be considerable enough to assist the Co-op in paying for major repairs, ongoing maintenance of the building, maintaining a reserve fund, and lowering monthly maintenance fees for the residents.” ...

. … The reduction in ACB for foreign taxes paid on behalf of a partner may occur prior to the addition to the ACB for the allocation of foreign income to the partner which is made on the first day of the following fiscal period [potentially triggering a negative ACB gain under s. 40(3.1)]. This position on s. 53(2)(c) overruled 2004-0075931E5, which stated: [P]aragraph 53(2)(c) does not provide for a deduction in computing the adjusted cost base of a taxpayer's interest in a partnership for the amount of any non-business income tax paid to a foreign country through the accounts of the partnership that was allocated to the particular partner …. ...

28 February 2001 External T.I. 2000-0016765 F- All or substantially all-- summary under Section 54.2 Summary Under Tax Topics- Income Tax Act- Section 54.2 CRA is prepared to issue rulings on the application of the all or substantially all test in s. 54.2, which is not necessarily a 90% of FMV test Regarding the meaning of the expressions “all or substantially all the assets used in an active business” in ss. 110.6(14)(f)(ii)(A) and 54.2, CCRA stated: FMV is generally the best measure for calculating “all or substantially all of the assets” of a business for the purposes of those provisions …. However … other units of measurement could apply since those provisions of the Act do not state any particular unit of measurement that must be used. ...

. … Although an arrangement can be entered into voluntarily, once an employer and Employee have entered into a formal hybrid work arrangement, the Employee would be deemed to be required to perform duties from the location agreed to in the arrangement. The formal hybrid working arrangement need not be in writing, provided that the details of the arrangement are agreed and clearly understood …. ...

., 11.5% * $100). Regarding s. 34(2), which required the determination of any excess of (A) the NBIT paid to each country, of $10, over (B) the amount deductible by Canco “in respect of the foreign investment income for the year” under ITA s. 126(1), CRA stated: [T]he wording of element B in subsection 34(2) of the TAO and the definition of “foreign investment income” in subsection 34(5) of the TAO require that the FTOP be apportioned among the countries in order to determine, for purposes of element B in subsection 34(2) of the TAO, “the amount deductible by the corporation in respect of the foreign investment income for the year under subsection 126(1)” on a country-by-country basis. ... The same result would be obtained when applying section 34 of the TAO to Country B. … In our view, the phrase “the amount deductible … under subsection 126(1) of the Federal Act” in subsection 34(2) of the TAO can be read as supporting the country-by-country allocation as described above in the circumstances. ...

., property described in s. 55(3.1)(c)(ii)(C)) – and concluded if the share issuance did not satisfy the “de minimis rule” by their FMV exceeding 10% of the FMV of the Pubco shares received by any TC when distributed, then s. 55(3.1)(c) would apply to exclude access to the butterfly exception. ... The de minimis rule would not apply since the FMV of the Pubco shares acquired by the unrelated persons would represent more than 10% of the FMV of the Pubco shares received by Aco ($20,000 x 10% = $2,000). Regarding Bco, the acquisition of the Pubco shares by the unrelated persons would come within the de minimis rule, as the FMV of such shares ($8,000) did not represent more than 10% of the FMV of the Pubco shares received by Bco on the distribution ($80,000 x 10% = $8,000). ...

10 September 2014 External T.I. 2014-0522551E5- Income for retired partner-- summary under Subsection 34.1(1) Summary Under Tax Topics- Income Tax Act- Section 34.1- Subsection 34.1(1) retroactive effect of s. 96(1.1) agreement to require s. 34.1(1) inclusion The "Retired Partner" retired from a partnership of individuals (the Partnership – which had an off-calendar fiscal period ending January 31 pursuant to an election under s. 249.1(4)) at the end of its January 31, 2014 fiscal period. ... Would the Retired Partner be required to report additional income under s. 34.1(1) representing 11 months of income for the period to December 31, 2014 – or could such income be deferred? ...

10 September 2014 External T.I. 2014-0522551E5- Income for retired partner-- summary under Subsection 96(1.1) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(1.1) retroactive effect of agreement to require s. 34.1(1) inclusion The "Retired Partner" retired from a partnership of individuals (the Partnership – which had an off-calendar fiscal period ending January 31 pursuant to an election under s. 249.1(4)) at the end of its January 31, 2014 fiscal period. ... Would the Retired Partner be required to report additional income under s. 34.1(1) representing 11 months of income for the period to December 31, 2014 – or could such income be deferred? ...

The term "group sickness or accident insurance plan" … includes accidental death and dismemberment insurance plans and disability and critical illness insurance plans. However, notwithstanding the exception in subparagraph 6(1)(a)(i), an employee must include, under paragraph 6(1)(e.1), in computing the employee’s income from an office or employment, the total of all amounts contributed in the year in respect of the taxpayer by the taxpayer’s employer to a group sickness or accident insurance plan, except to the extent that the contributions are attributable to employment insurance benefits paid on a periodic basis pursuant to paragraph 6(1)(f), excluding subparagraph 6(1)(f)(v). … In addition, despite the exception in subparagraph 6(1)(a)(i), subsection 6(4) could apply to confer a taxable benefit on an employee respecting premiums paid by the employee’s employer in respect of a group term life insurance policy calculated in accordance with the provisions of sections 2700 to 2704 of the Income Tax Regulations (the "Regulations"). ...