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Consequently … the hypothecary creditor will not be able to include in the calculation of its capital dividend account the proceeds of a life insurance policy that it has received in payment of the debtor policyholder's debt because such proceeds are received only by the policyholder. ...

. … [T]he trips made by Employee A between his home and the Y service point on Tuesday and Thursday of each week are of a personal nature. ...

5 December 2002 External T.I. 2002-0172315 F- Contingent Right to Acquire Shares-- summary under Paragraph 251(5)(b) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b) ss. 251(5)(b) and 256(1.4) applicable where the 3 equal shareholders agree that they must purchase the shares of anyone committing fraud – but not if redemption requirement The three equal unrelated individual shareholders of Opco (Messrs. ...

In the current situation … the estate replaces the taxpayer. …[I]t would therefore be possible for the estate to deduct from its income the amount of damages paid if it results from acts engaged in by the entrepreneur while carrying on his business and if this amount of damages is otherwise deductible in accordance with the requirements of IT-467R2-Draft ...

Thus … the block size would be 100 and thus if there were 100 unitholders of the first series each holding at least 100 units, and there would have to be at least 50 unitholders of the second series, each holding at least 100 units. ...

Before indicating that such fee could be deducted in accordance with s. 20(1)(e) provided that it was “incurred in the course of borrowing money used to earn income from a business or property and that it [was] reasonable,” CRA stated: [P]aragraph 20(1)(e.1) … does not have application because the guarantee fee is paid in respect of the term of the loan rather than with respect to the year in which it is paid. ...

In that case, the vehicles must be reclassified, from that point onwards, in another Class …. ...

CCRA also indicated: [T]he reserve included in computing business income pursuant to subsection 34.2(5) for the taxation year subsequent to the year in which a taxpayer ceases to carry on business will not be included in earned income …. ...

. … In this case, the facts submitted are clearly insufficient to allow us to conclude whether or not the XXXXXXXXXX office constitutes a fixed place of business for Canco. ...

Consequently … the estate may designate the portion of the property that you occupied as your principal residence since its acquisition. ...