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Furthermore … the Purpose Test contained in subsection 55(2) must, as a technical matter, be considered in respect of a disposition of any share of the capital stock of XYZ Corp. Scenario 2 [S]ubsection 55(2) would apply in respect of the deemed dividend received by Bco … to the extent that the dividend could reasonably be considered to be attributable to something other than safe income on hand, attributable to the shares of the capital stock of XYZ Corp. held by Bco and before the "safe income determination time" …. [P]aragraph 55(3)(a) would not apply to exempt the dividend … [as] the repurchase by XYZ Corp. … would come within subparagraphs 55(3)(a)(i), (ii), (iii) and (v). ...

. … Clause 56(1)(a)(i)(C.1) does not apply to include an amount in income to the extent the amount would not be subject to income taxation in the U.S. if the Taxpayer were resident in the U.S. … You have indicated that [the] return of the investment in contract would be excluded from income for U.S. income tax purposes. Based on this…the amount of the Withdrawal would not be included in computing the Taxpayer’s income …. … [T]he same [would apply] if the Withdrawal took place in a year subsequent to the Taxation Year in which the Deemed Distribution took place … [or] if the Taxpayer was a U.S. citizen, rather than a green card holder, who renounced this US citizenship after becoming a tax resident in Canada … [subject to] subparagraph 4(a) of Article XXIV of the Convention …. ...

18 September 2012 External T.I. 2011-0423941E5 F- Entreprise de prestation de services personnels-- summary under Subparagraph 18(1)(p)(ii) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(p)- Subparagraph 18(1)(p)(ii) cost of benefit to corp generally equals allowance amount and can be the cost of a non-s. 6 benefit – however no benefit if cell phone used primarily in course of employment What is meant by "the cost of … any benefit or allowance," and does this differ from the amount of the benefit conferred on the employee? ... For an allowance, this will usually be the amount of the allowance paid to the employee. … [A] corporation carrying on a PSB … would not be able to deduct the cost associated with a motor vehicle made available to an incorporated employee. In the case of an operating expense benefit, it is our view that a corporation carrying on a PSB could deduct the amount of such expenses that it pays and that are included in the calculation respecting the employee. … [A] corporation carrying on a PSB may deduct the costs of benefits and allowances conferred on an incorporated employee without being limited to the benefits and allowances referred to in paragraphs 6(1)(a) and 6(1)(b). … In the case of a cellular telephone that is provided by a PSB corporation to an incorporated employee, there will be no benefit to the employee if the employee uses the telephone primarily for the purpose of the employee’s employment. ...

14 July 2020 External T.I. 2020-0843071E5- TFSA- Deliberate Over-contributions-- summary under Deliberate Over-Contribution Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Deliberate Over-Contribution restrictive paraphrase provided of the deliberate over-contribution definition In response to an inquiry as to the consequences to an individual who intentionally makes a TFSA contribution in excess of the available contribution room, CRA indicated: Section 207.02 … provides that an individual who makes a contribution to a TFSA that exceeds their contribution limit is subject to a 1% tax … based on the individual’s highest “excess TFSA amount” for [each] month …. ... The portion of the withdrawal relating to the investment earnings is included in the individual’s income … [under] section 207.061. ... The advantage tax continues to apply until the individual withdraws the deliberate over-contribution and the associated income and capital gains from their TFSA. … [T]he CRA closely examines any unusual TFSA transactions and will challenge aggressive tax planning where appropriate. ...

. … [U]nder normal accounting practices, “percentage of completion” is a method that reports revenue of a service contract over a period of time (i.e., performance obligations under the contract have been satisfied on an ongoing basis by the entity). ... Accordingly … the revenue reported by the entity under the percentage of completion method would generally be considered “qualifying revenue” …. ... Accordingly … the unrealized gains/losses reflected in an entity’s financial statements arising from mark-to-market adjustments to the carrying value of an investment … are not considered qualifying revenue …. ...

. … [W]here it can be determined … that the option is granted in consideration for services that are to be rendered after the time of grant and upon the fulfillment of a condition or contingency, the income should instead be recognized when the services are rendered, the amount is quantifiable and the rights are unrestricted. … [Here] the vesting of the option is linked to the completion of the long-term research project. As such, it may be difficult to conclude that the income is earned before the vesting date under the particular arrangement. … [G]enerally, it is at the time where the services have been rendered and the contingency has been fulfilled, that the FMV of the underlying share over the aggregate of the exercise price of the option should be included in income under subsection 9(1). … … Where the facts indicate that the incremental value represents part of the consideration received by the taxpayer for consulting services rendered, the incremental value should generally be treated as business income for purposes of the Act. ...

8 February 2011 External T.I. 2011-0392401E5 F- Crédit d'impôt pour frais médicaux-- summary under Subsection 118.4(2) Summary Under Tax Topics- Income Tax Act- Section 118.4- Subsection 118.4(2) expenses of Quebec massage therapists were ineligible In indicating that expenses paid to Quebec massage therapists were ineligible for the credit, CRA stated: It is therefore necessary to determine whether the applicable provincial legislation … includes massage therapists with medical practitioners which, according to our understanding of that legislation, would not appear to be the case. For the same reason … Chevalier … 2008 TCC 11 … concluded that the fees paid for the services of a naturopathic doctor and an osteopathic practitioner did not qualify for the medical expense tax credit. ...

. … [S]ubsection 13(3) of the Copyright Act … states that, unless otherwise provided by contract, copyright in a work created in the course of employment is the property of the employer and not of the author. That being said … F 2002-0149781R3 [found] that a right to royalties from SOCAN constituted "eligible property" …. ...