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Taxpayers are expected to have full access to the information pertaining to their obligations or entitlements under the ITA – and to the extent these obligations are not met, CRA will exercise the powers under the ITA to enforce compliance with tax laws and maintain the integrity of the tax system. ...

However: [If] the non-resident student attending a university outside Canada ceased to be resident in Canada in a previous year, at or after leaving Canada, in order to attend that university … the student would be deemed, under paragraphs 115(2)(b) and (d), to have been employed in Canada during the year for the purposes of subsection 2(3). ...

. … [T]he potential for having to repay a sum under a warranty clause would not be sufficient in itself to indicate that the sum in question is not earned. ...

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. ...

The correspondent: noted that the "acquisition" or "sale of stock index futures is similar in nature to a transaction in "naked options" in that no property is actually purchased or sold and, further, that paragraph 25 of … IT-479R states that, while transactions in "naked options" are normally on income account, the Department will accept the reporting of gains or losses on capital account provided this practice is followed consistently from year to year. ...

CRA stated: [A]s indicated in … IT-479R …[t]he CRA generally presumes that: (a) the gain or loss realized by a holder of options is on the same account as the holder's transactions in shares; (b) the gain or loss realized by a writer of covered options is on the same account as the underlying shares; and (c) the gain or loss realized by a writer of naked options is normally on income account. ...

The Agency stated: [N]o share acquired from that corporation will come within paragraph (b) … as long as the Taxation Act (Quebec) grants a tax credit to any taxpayer for the acquisition of shares of that corporation. ...

. … In the case where the same date in the next calendar month cannot occur because that next calendar month has a lesser number of days, the first month would end on the last day of that next calendar month. ...

On December 31, 2016, Opco had accumulated $100,000 in after-tax profits and safe income, As there were 200 outstanding AA and X shares, the X class shares had a redemption value on January 1, 2017 of $50,100 (($100,000 x 100/200) + $100 of PUC) On January 1, 2017, Opco paid a dividend of $50,000 to Holdco. ... After noting the Robertson rule that “income will be attributable to a particular class of shares in the same ratio in which each class would be entitled if all earnings of the corporation, but not share capital, were to be distributed,” CRA stated: [G]iven that…the Class X and AA shares were entitled to an equal share of Opco’s profits following the issuance of the Class X shares and that the value of the shares of each class would increase due to this share of profits, … the safe income earned or realized annually following the issuance of the Class X Shares could be proportionately allocated based on the number of shares of each class. ...

The safe income reasonably contributing to the capital gain on the 25 common shares of the capital stock of OPCO held by Trust A and Trust B is $59,940 (149,975 / 249,875 X 99,900) and the safe income reasonably contributing to the capital gain on the 100 preferred shares held by Trust A and Trust B is $39,960 (99,900 / 249 875 X 99,900). ...