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Accordingly … the individual may include charitable gifts made in the five previous taxation years, to the extent such gifts were not included in computing the individual’s charitable donation tax credit of those prior years, and subject to the limits described in section 118.1 of the Act. ...

After indicating that s. 56(1)(a)(i) applies to any amount received by a taxpayer in the year as, on account or in lieu of payment of, or in satisfaction of, a superannuation or pension benefit even if it is in the nature of a single payment, and that “s. 56(1)(a)(i) … applies equally to benefits from a foreign pension plan that are attributable to services rendered while the individual was not a resident of Canada,” CRA stated: In accordance with Article 18(1) of the [Canada-Chile] Treaty, pensions arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in the Contracting State in which they arise. ...

CRA indicated that to the extent that the Government Assistance received by Aco was in respect of the acquisition of depreciable property (or land), s. 13(7.1) (or s. 53(2)(k)) will deem that amount to reduce the capital cost of the depreciable property (or land) – without any inclusion under s. 12(1)(x) pursuant to s.12(1)(x)(vi) and without any election required. ...

. … To the extent that an election is made under subsection 12(2.2), the inclusion under paragraph 12(1)(x) will be reduced pursuant to subparagraph 12(1)(x)(vii). ...

. … CRA went on to note: The reduction in ACB for foreign taxes paid on behalf of a partner may occur prior to the addition to the ACB for the allocation of foreign income to the partner which is made on the first day of the following fiscal period. ...

In that case, the municipality is merely acting as a conduit for the other person, and it is our view that amounts received by the municipality on behalf of the other person do not qualify as gifts to a municipality …. ...

CRA indicated that the first alternative did not satisfy the requirement, for the equipment to qualify as Class 53 property, that it be used in the manufacturing or processing of goods for sale – as the goods (the dental restorative products) instead were used in providing a dental service. ...

It claims an Atlantic Investment Tax Credit (“AITC”) pursuant to s. 127(9) of $750,000, being 10% of the capital cost, again reduced to $7,500,000 by the NS CITC “government assistance” – and receives the AITC by way of credit against federal tax payable in the current year or during the carryforward or carryback period. ...

. … [I]t is our view that the First Parking Space is a component of the housing unit (i.e., the Condo). ...

CCRA stated: [T]he Agency's position … is that a corporation that redeems shares held by one of its shareholders may pay its entire capital dividend account to that shareholder, provided that subsection 83(2.1) does not apply. ...