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. … Expenses paid to a “private health services plan” as a premium, contribution or other consideration in respect of, among others, the individual or the individual's spouse generally qualify as medical expenses under paragraph 118.2(2)(q) except to the extent that the payment was deducted by the individual as a business expense under subsection 20.01(1). ...

. … [F]or an individual disability insurance policy to be a component of a group insurance plan, it must be determined whether the level of benefits and the ratio of contributions to the plan shared by the employer and the employee are similar to those of the other employees covered by the same plan. ...

After noting that there would be no taxable benefit under s. 6(1)(a) from the employer's payment of the premiums if this arrangement qualified as a group plan described in s. 6(1)(a)(i), CRA went on to note that its general presumption “that an employee shareholder receives benefits or allowances in their capacity as a shareholder if they can significantly influence the policies of the corporation” can be rebutted if “all employees of the corporation are entitled to the benefit” or if all employees are shareholders or related to a shareholder and the benefit “is comparable (in nature and amount) to the benefits … generally offered by corporations of the same size to non-shareholder employees whose services and responsibilities are similar.” ...

Consequently, in the example … a trust created for a minor child under the will would be considered a “testamentary trust” under the definition in subsection 108(1), assuming that paragraphs (a), (b) and (c) of that definition do not apply. ...

. … [N]o partner should be allocated an amount of income greater than the income realized by the partnership. ...

However, as the unanticipated fugitive emissions occur within Bco’s pipeline transportation network, Aco may be able to avail itself of the relief provided in subsections 211.92(6) and (7) … because such emissions would likely be due to extraordinary circumstances outside of the control of Aco. ...

However, as the unanticipated fugitive emissions occurred within Bco’s pipeline transportation network, “Aco may be able to avail itself of the relief provided in subsections 211.92(6) and (7) … because such emissions would likely be due to extraordinary circumstances outside of the control of Aco.” ...

24 June 2025 External T.I. 2025-1063501E5- Clean Hydrogen ITC- Operating Year-- summary under Operating Year Summary Under Tax Topics- Income Tax Act- Section 127.48- Subsection 127.48(1)- Operating Year periods where hydrogen continues to be produced are not disregarded The concept of an “operating year” is defined to “disregard … any period during which the project is not operating”, so that, for example, if it did not operate for one month, the operating year might be 13 months. ...

The proportion of 70% of the salary earned by the Physician could be considered to be situated on the Reserve and would therefore be exempt from tax …. ...

Regarding whether s. 15(2) applied, CCRA indicated that the expression "person … connected with a shareholder" in s. 15(2) may include a partnership connected with a shareholder and that, under the pre-2011 version of s. 15(2.1), a person is connected with a shareholder of a particular corporation if the person does not deal at arm's length with the shareholder, which was a question of fact. ...