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CRA stated: [T]here is no taxable benefit where an employee uses an Employer's automobile to drive from his or her home to the … customer. ...

.] … Variable B of the FAPI definition applies specifically to capital gains, whereas income from a business other than an active business, such as income from the sale of property which meets the conditions of paragraph 95(2)(a.1), would fall under variable A of that definition. ...

[A] similar conclusion was arrived at in… Menzies …. [S]ubsection 244(20) relieves the Minister from its obligation to send a notice of determination to each person who was a member of the partnership during the fiscal period covered by the notice of determination where the notice of determination is mailed to, served on or otherwise sent to the partnership at the latest known address of the partnership. ...

. … [W]here capital property is transferred by Taxpayer A to Taxpayer B in settlement of rights arising out of their marriage or common-law partnership (see paragraph 73(1.01)(b) and subsection 73(1)), Taxpayer A will be deemed to have disposed of the shares for proceeds equal to Taxpayer A’s adjusted cost base (ACB) of the shares immediately before the disposition. ...

. … In conclusion, a corporation that becomes subject to CMT will be required to determine its eligible losses for a particular taxation year as if it had been subject to CMT in previous taxation years. ...

. … [T]he premiums received by the Taxpayer could now fall within amended variable E of the definition of CEC, assuming that the amounts…have [not] reduced the amount of an outlay or expense, (i.e., …if a reduction to paragraph 20(1)(c) did not apply as discussed above.) ...

. … [T]he transaction changed the whole substratum or “raison d’etre” of the Trust. ...

CRA indicated that the company providing the trips should issue T4A slips to the individual proprietor, or to the individual receiving the trip as a benefit qua employee of the individual’s personal corporation – whereas no T4A slip is required if the trip was received as a benefit qua shareholder of the personal corporation (a distinction which in practice would be difficult or impossible for the trip provider to apply). ...

In this regard, the T2 Corporation Income Tax Guide … states that the Part I tax payable for the year is the basic Part I tax plus the amount of surtax, the amount of recapture of the investment tax credit, and the refundable tax on the Canadian-controlled private corporation’s investment income, minus any allowable deductions and credits, including the federal tax credit for forestry operations. ...

The TSO proposed to designate pursuant to s. 80(16) the maximum amounts permitted under ss. 80(7) and (11), so that the forgiven amount would be applied first against the balance of the non-capital loss, second as to reduce ¾ of the cumulative eligible capital and third, to reduce the adjusted cost base of the related corporation shares under s. 80(11), resulting in an amount being deemed to be a capital gain from the disposition of capital property under s. 80(12). ...