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. … [T]he fact that provincial insurance law may exempt a charitable organization from the application of certain legislative requirements with respect to the issuance of charitable gift annuities does not amount to the organization being licensed or otherwise authorized under that law to carry on an annuities business in Canada. ...

The bonuses described in examples 4 and 6 of the … Folio [S3-F10-C3] and the rebates of mutual fund commissions discussed at paragraphs 3.36 and 3.37 are (or are analogous to) a return on the amounts invested from the registered plan with the financial institution. ...

CRA responded: [I]n the situation where the Spouse is named as the sole beneficiary of an unmatured RRSP or RRIF … in the RRSP or RRIF contract, the T4RSP or T4RIF slip will be issued in the Spouse's name where all of the following conditions are satisfied: the Spouse is named as beneficiary in the RRSP or RRIF contract (Footnote 13) of all the property held in the RRSP or RRIF; the entire refund of premiums in the case of an RRSP, or the eligible amount of the benefit designated under subsection 146.3(6.11) in the case of a RRIF, is transferred directly, under paragraph 60(l), to an RRSP or RRIF under which the Spouse is the annuitant or the funds are used to purchase an eligible annuity under which the Spouse is the annuitant; before December 31 of the year following the year of death, all property held in the RRSP or RRIF is distributed. ...

CRA responded: [I]n the situation where the Spouse is named as the sole beneficiary of an unmatured RRSP or RRIF … in the RRSP or RRIF contract, the T4RSP or T4RIF slip will be issued in the Spouse's name where all of the following conditions are satisfied: the Spouse is named as beneficiary in the RRSP or RRIF contract (Footnote 13) of all the property held in the RRSP or RRIF; the entire refund of premiums in the case of an RRSP, or the eligible amount of the benefit designated under subsection 146.3(6.11) in the case of a RRIF, is transferred directly, under paragraph 60(l), to an RRSP or RRIF under which the Spouse is the annuitant or the funds are used to purchase an eligible annuity under which the Spouse is the annuitant; before December 31 of the year following the year of death, all property held in the RRSP or RRIF is distributed. ...

28 September 2020 External T.I. 2019-0800551E5- Provincial Residency of a TFSA Trust-- summary under Subsection 2601(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 2601- Subsection 2601(2) office of investment manager was PE to which securities trading income of TFSA was allocated When asked where a self-directed TFSA was resident, CRA indicated that the trust would always be resident where its central management and control was factually exercised by the trustee – irrespective of the level of involvement of the TFSA holder in the decisions. ...

Since the benefit … arises from the issuance of shares, paragraph 7(3)(b) precludes a deduction by EmployerCo in respect of that benefit. ...

In such case … the Limited Partnership’s proposed acquisition and ownership of the Furniture for the purpose of furnishing the rental units in the Residence would not be a distinct activity that is separate from its activity of leasing real property. ...

The determination of whether a Payment is included in qualifying revenue and/or excluded from qualifying revenue on the basis that it is an extraordinary item is a question of fact …. ...

Unless the Payments were considered qualifying revenue, the Contractors would qualify for the CEWS – but if they receive it, the Operator will reduce future amounts paid by a corresponding amount. ...

If the PF is an EBP, the amounts received therefrom would be taxable under s. 6(1)(g), subject to exceptions including that in s. 6(1)(g)(iii) regarding pension benefits received out of the plan that are attributable to services rendered by a person while a non-resident in Canada – as to which there would be fully taxability under s. 56(1)(a)(i) regardless of non-deductibility of contributions to the plan or a foreign tax exemption for the benefits. ...