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Based on this information, we are of the view that those plans generally satisfy the definition of the term "forest management plan" as currently defined in the Explanatory Notes …. … [I]t is not the forest engineer's report setting out the development expenditures eligible for the property tax refund that constitutes a "forest management plan" for the purposes of subsections 70(9) and 73(3), but rather the certified forest management plan that the taxpayer filed to obtain forest producer status under section 120 of the Forest Act. ...

(a)(i) of the Definition, CRA stated: [T]he Act's use in subclause (a)(i)(B)(I) of the Definition of the definite article in the phrase "other than the private corporation" is not intended to refer to only one private corporation at a time, that is, the one that would be considered for purposes of clause (a)(i)(A) in respect of a particular item of income, but rather … "the private corporation" refers to each of the private corporations that come within the preamble to clause (a)(i), which refers to "a private corporation.” Thus, the expression "the private corporation", used in subclause (a)(i)(B)(I) of the Definition, refers to any private corporation that is described in the preamble to paragraph (a)(i) and that satisfies the condition in clause (a)(i)(A). … In your example, this means that at most only 80% of Opco B's income is derived from the supply of property or services to persons (other than the private corporations Opco C and Opco D) with which it deals at arm's length. ...

CRA responded: Since a taxpayer’s recapture and terminal loss are included or deducted from income, respectively, under subsections 13(1) and 20(16) … and are not included in income under paragraph 20(1)(a) … these amounts would be reflected in an EPOP’s income amount for purposes of paragraph 1100(0.1)(c) of the Regulations where they relate to the same source of income that is a business or property in which the relevant DIEP is used for the EPOP’s taxation year. ...

30 January 2024 External T.I. 2024-1005011E5- Safe income-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) dividend income that has not been subject to tax should not constitute safe income, and double taxation can be avoided with proper structuring The starting structure in Example 30 of “ CRA Update on Subsection 55(2) and Safe Income ” is that Holdco owned the shares of Opco with an FMV, ACB and safe income of $500, 0 and 0; and Opco owned Subco1 (whose shares also had an FMV, ACB and safe income of $500, 0 and 0) and Subco2 (whose shares had no value, ACB or safe income). ...

Consequently, Wind Turbines and their concrete foundations are fixtures …. ... As all components of the Solar Equipment are attached to the land on which they are situated, it is our view that the Solar Equipment is described in paragraph (a) …. ...

(Tax Window, No. 30, p. 5, ¶2462)-- summary under Subsection 6205(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 6205- Subsection 6205(2) The test in Regulation 6205(2)(a)(ii)(A) would not be met where two individuals each owning ½ of the common shares of a corporation exchange their common shares of the corporation for preferred shares and have the corporation issue common shares to individuals related to one or other of the two shareholders, because "all" of the common shares would not be owned by non-arm's length persons. ...

8 December 2011 External T.I. 2011-0421051E5- Principal residence- Bed and Breakfast-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence- Paragraph (e) In providing a brief review on whether operating a bed & breakfast (B&B) on a property would make the principal residence exemption unavailable on that property, CRA indicated (referring to para. 32 of IT-120R6) that "whether use of a portion of the property as a B&B operation is ancillary to the main use of the property as the taxpayer's principal residence are ultimately questions of fact. ...

. … [A]n amount paid for a medical service that relates to an existing medical condition or illness, for example, infertility, would likely qualify as a medical expense…. ...

25 October 2013 External T.I. 2013-0491141E5 F- Sens d'« agriculture »- Meaning of « farming »-- summary under Farming Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Farming assistance of consultant not included in farming In response to a query on agronomic monitoring, CRA stated: [T]he definition of "farming" … does not include the situation where an individual is limited to advising and assisting the farming activities in all their farm management aspects and, for so doing, receives fees. ...

19 January 2017 External T.I. 2015-0576751E5 F- Trust, Disposition of depreciable property, Assumption-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) trust cannot have a NAL relationship with itself CRA agreed that the ½ step-up rule in s. 13(7)(e) does not apply to a deemed disposition under s. 104(5) given that the trust is not related to itself and does not otherwise not deal at arm’s length with itself. ...