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After noting that such policy did not apply to cash equivalent gifts and awards, such as where the employee receives reward points, which are accumulated and can be redeemed for a choice of goods, CRA stated that there could be “arguments that the points may not constitute a cash or cash equivalent award … since the points cannot be converted into cash and the number of goods that the employee can acquire, in exchange for the accumulated points, is very limited.” ...

. … [I]f the trust continues to exist after deregistration and the shares of the cooperative are not transferred to the annuitant in the year of deregistration or are transferred in a year subsequent to the year in which subsection 146(12) applies, we are of the view that no withholding tax is required under the application of the provisions of the Act and Regulations since no payment is made on deregistration and in the year of deregistration. ...

. … [I]n 2002, the partner did not elect to add back income from that business pursuant to subsection 34.1(2). ...

. … [U]nlike paragraph 251(5)(b), the definition of term preferred share does not contain the exception that applies where one or more of the rights referred to in that provision cannot be exercised at that time because the exercise of the rights in question depends on the death, bankruptcy or permanent disability of an individual. ...

. … Where an employee elects to receive the amount of the retiring allowance in instalments, it is our view that the instalments will be taxable in the year they are received. ...

. … [T]he Court's judgment had the effect of crystallizing the amount receivable and making it payable to the Taxpayer retroactively from the date of the summons. ...

3 November 2004 Internal T.I. 2004-0083791I7 F- Paragraphe 44.1(2)-- summary under Subsection 44.1(8) Summary Under Tax Topics- Income Tax Act- Section 44.1- Subsection 44.1(8) pre-condition of carrying on business not satisfied / general overview provided A newly-formed corporation used its cash share subscription proceeds almost entirely to purchase a piece of land for which, to date, a required zoning change has not yet been obtained. ...

Regarding whether the Minister could reassess XCO directly to change the partnership income allocated to it, the Directorate stated: [T]he Minister could reassess pursuant to subsection 152(4) at the level of the XCO general partner, in respect of the tax that would be payable by XCO for the Particular Taxation Year, in order to, inter alia, modify the amount of its share of the income from BCOM that was included in the computation of its income … without a determination being made at the level of BCOM pursuant to subsection 152(1.4), and without assessments at the level of BCOM partners being made pursuant to paragraph 152(1.7)(b). ...

“Where participating shares are exchanged for preferred shares having a FMV and a redemption value equal to the FMV of the participating shares, and because of the application of subsection 51(1) to the exchange, the ACB of the preferred shares is equal to the ACB of the exchanged participating shares, then the portion of the income earned on hand attributable to the participating shares immediately before the exchange is transferred to the preferred shares” – so that $8 million safe income of the Class A shares transferred to the 10,000 Class B shares. ...

. … [T]he CCRA considers overtime to be of an occasional nature if it is worked less than three (3) times per week. ...