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. … [T]he phrase “to or for an individual” in subsection 146.1(2.21) must apply in respect of a living individual and an EAP cannot be paid in respect of a beneficiary once the beneficiary in question is deceased. ...

Standard Life took essentially the opposite approach to the interpretation of a similar requirement under s. 138(11.3) – so that it was necessary for the taxpayer to qualify as an "insurer" in the preceding taxation year rather than only in the current year, in order for an asset bump to be available. ...

(b) of 233.3(1) – “specified foreign property,” CRA stated: We wish to clarify that a specified foreign property can include inter alia tangible or intangible property…., real property can include… intangible property…[and] a mineral right would likely be considered an intangible property. ...

After referring to “the CRA’s long standing treatment of foreign taxes paid by a partnership for purposes of the foreign tax credit rules in section 126 and the findings… in Smidth … (2012 TCC 3, aff’d 2013 FCA 160)," CRA stated: a partner’s non-business income tax, within the meaning of subsection 126(7), paid to a particular foreign country includes the partner’s share of any non-business income tax paid to that country through the accounts of the partnership. ...

In other words, the settlement of a commercial debt that results in the application of section 80 automatically and immediately reduces the NCL balance for a taxation year because of the D.2 element of the NCL definition in subsection 111(8). ­­­­­­­­­­­­­­­­­­­­­­­ ...

. … Given that the employer acted on behalf of the employee by paying an invoice that otherwise would be borne by the employee, we are of the view that the amounts were constructively received by the employee. ...

As a result, the total amount of the allowances, as well as meal vouchers, should be included on the T4 slip in box 14 …. ...

1 March 2012 Internal T.I. 2012-0437901I7 F- Timing of the adjustments pursuant to 111(5)-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) acquisition of control of target does not reduce its NCLs at that time – streaming rules apply prospectively A corporation acquired all of the shares of a target corporation, resulting in an acquisition of control, and a day later, they amalgamated to form "Amalco". ...

. … [I]t appears to us, based in particular on the conflict of law rules, that the provincial and territorial laws of property and civil rights in Canada provide for mutual recognition of different types of entities or arrangements established under the respective jurisdictions of the various provinces and territories, thus providing an expanded base for analysis that is uniform across Canada for the purposes of applying the two-step approach. ...

. … Normally, an employee is not required to repay a salary advance as long as he or she continues to perform the services (i.e., remains employed). ...