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. … [T]he settlor, in this case the Employer, has not transferred any amount from its patrimony. ...

On the other hand, since Corporation A received advance payments in respect of goods processing services to be performed after the end of the taxation year, these amounts come within paragraph 12(1)(a) …. ...

The exception in s. 6(1)(b)(vii.1) was not available as the employees were not travelling in the performance of the duties of their employment, as to which the Directorate stated: In the absence of services rendered to the employer during the period of travel, the employee does not travel in the performance of the employee’s duties …. ...

Before finding that Non-Resident Corporation did not have a permanent establishment in any province for purposes of Part IV of the Regulations, the Directorate stated: Article XVI of the Convention … applies without regard to, inter alia, Article VII of the Convention, and... permits Canada to tax income derived by a non-resident company from performances in Canada without requiring that such income be earned through a permanent establishment in Canada under the Convention. ...

In the present case … [it] may be permitted in the context of a reassessment. ...

Given … Byram, we do not believe that Mr. A's loss should be deemed to be nil solely because the Corporation's shares were acquired by the RRSP and not personally by Mr. ...

. … [T]ime spent on the road, on the premises of properties for sale, and at the real estate broker's place of business cannot be assimilated to time spent working at the home office. ...

4 December 2007 Internal T.I. 2007-0237461I7 F- Définition d'activité de construction-- summary under Subsection 238(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 238- Subsection 238(2) construction activities included cable installation, maintenance and upgrading/primarily means over 50% The taxpayer, which had queried whether it was required to file T5018 slips for payments made to subcontractors, was engaged in the installation of cabling, both public and residential lines – and also was involved in the construction of overhead and underground cables, the installation of equipment, the maintenance and renovation of networks, the interior and exterior pre-wiring of buildings and the installation and servicing of certain products. ...

In finding that this was a prescribed prize, the Directorate stated: [T]he prize of excellence … was publicly recognized. ...

. … [T]here is no jurisprudence dealing with filling the hole in a situation such as the one under review. ...