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After finding that there was no exemption for the diplomat in Art. 34 of the Vienna Convention on Diplomatic Relations from the s. 162(7) penalty as the property " was not held on behalf of the sending State as part of the mission," nor was there any exemption for the child, CRA stated that "you may wish to consider exercising discretion in assessing the penalty given that….there was a loss on the property. ...

19 October 2005 Internal T.I. 2005-0151211I7- Financing expenses-- summary under Paragraph 20(1)(e.1) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e.1) indirect use test inapplicable to s. 20(1)(e) or (e.1), and “relate solely to … year” test not satisfied by lump sum issue fee reimbursement to parent A Co, a public company, issued interest-bearing debentures to arm's length parties, and on-lent the borrowed money to its "great-grandchild" subsidiary (D Co) at the same interest rate. ...

Deloitte & Touche Inc., [2007] 2 C.T.C. 253, 30 C.B.R. (5th) 81, (Sask. ...

In this context, the use of the terms "action de remplacement " and "share for which the affiliate share was substituted" in the French and English versions of paragraph 93(2.01)(a) refer to the concept governed by paragraph 248(5) in respect of property that is shares. ...

. … There is a logical connection between the income from ULC and the U.S. taxes paid by Taxpayer because if Taxpayer did not own such shares, no U.S. taxes would have been paid [citing Smidth]. ...

The Directorate stated: The fact that employment income from 1979 to 1981 was exempt … is not in itself determinative of the taxpayer's entitlement to the paragraph 8(1)(m) deduction in 2006. Consequently … the Contributions may be deducted in computing the taxpayer's taxable employment income in 2006 to the extent permitted by subsection 147.2(4). … Where an expense relates to both on-reserve and off-reserve income … the taxpayer must prorate the expense in question to determine the taxpayer's net employment income that is exempt …. ...

In this context, the use of the terms "action de remplacement " and "share for which the affiliate share was substituted" in the French and English versions of paragraph 93(2.01)(a) refer to the concept governed by paragraph 248(5) in respect of property that is shares. ...

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Consequently, paragraph 8(1)(b) does not apply to allow the deduction … of legal costs that have been paid to recover such an amount. [Respecting the recovery regarding the Coverage] … we suggest that a deduction be allowed for the amount of the legal fees that were paid to recover the damages for the Coverage. … You stated that the Dismissal Amount is a taxable amount as a wage or salary or retiring allowance. Thus, we are of the view that the amount paid as a legal expense attributable thereto is deductible in computing the Objectors' income under paragraph 8(1)(b) or 60(o.1) …depending on the circumstances. … [T]here is no rule in the Act for the allocation of legal fees. … [I]t is reasonable to consider that legal fees should be allocated among the various components. ...