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CRA responded: [A]s there is no income that is received (directly or indirectly, in any manner whatever) from the provision of services or property between ACo and BCo, there would not be any income that would be as described in subparagraph (a)(i) of the SCI definition …. ...

CRA then stated: Following [Poulin], we accept … that an amount for damages may be deducted in a year in which a taxpayer no longer carries on business, since the taxpayer is presumed not to have ceased carrying on business for as long as the taxpayer is engaged in carrying through on acts committed to by the taxpayer in the course of the business, even if, at the time the amount is deducted, the taxpayer is no longer transacting and can no longer attend to the taxpayer’s customers. ...

The individual’s taxable capital gain arising from the transfer of the capital property to the CRT would not be included in variable B …. ...

In responding affirmatively, CRA stated: [S]ection 122.92 … does not require that an eligible dwelling be built prior to, or concurrently with, a secondary unit in order for qualifying expenditures to qualify for the MGHRTC. ...

Where a contribution is made in respect of new or future hires comprised of unidentified individuals, most of whom are not yet employees of the employer, this requirement would not be met and the contribution would not be deductible under subsection 144.1(6) …. ...

23 March 2023 External T.I. 2023-0967391E5- Incentive for nurses to go back to practice-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) s. 56(1)(r)(i) rather than s. 5(1) applies to inducement payments made by the government directly to a prospective employee of a hospital CRA indicated that where a provincial government sponsors a program that is designed to deliver incentive payments or earnings supplements directly to eligible nurses, such amounts are included in their income under s. 56(1)(r)(i) (“earnings supplements provided under a [government-sponsored] project … to encourage individuals to obtain or keep employment”) whereas if it sponsors a program designed to have employers deliver the payments directly to them, such amounts are included in their employment income under s. 5(1). ...

After noting that the (apparently Quebec) statutory provisions governing an IMB are similar to those governing a CBCA corporation, including providing that the IMB is a legal person (“personne morale”), has limited liability, except in relation to certain borrowings, has a board of directors and is governed by by-laws and resolutions – and the interests in it carry voting rights, CRA concluded that such an IMB qualifies as a corporation. ...

For general guidance on when a modification to the rights and privileges attached to a share may, or may not, result in a disposition, see … IT-448 [paras. 9-16]. ...

…[I]f it can be shown that there is a sufficiently clear connection between the death of the deceased parent and the disposition of the housing unit by the child beneficiary, then it may be possible to conclude that the disposition of the housing unit by the child beneficiary can reasonably be considered to have occurred due to the deceased parent’s death, and the gain realized on the disposition would not be deemed to be business income by virtue of the application of subsection 12(12) …. ...

. … Where it can be established that a taxpayer has disposed of a housing unit located in Canada, which was owned for less than 365 consecutive days, due to or in anticipation of the inability or lack of means to pay their debts as they become due, then the housing unit will not be considered a flipped property. ...