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. … It appears to us that in the circumstances you would be justified in considering that Mr. ...

The Directorate stated: [U]nder the terms of subsection 231.5(1) … where, pursuant to sections 231.1 and 231.2, electronic records (such electronic records being "records" within the meaning of the definition of "record" in section 231 and the definition of "record" in subsection 248(1)) are being audited or reviewed or produced, the person who is doing the auditing or reviewing, or to whom the production is made, or any CCRA official, may make or cause to be made electronic copies of them. ...

In finding that the taxpayer would not be required to pay interest pursuant to s. 161(1) notwithstanding s. 161(7)(a)(iv), the Directorate stated: 9733167 … confirmed that interest should not be calculated by pursuant to subsection 161(1) or (2) where a deduction is substituted by a carryback of losses, tax credits or other amounts from subsequent years and this does not change the original assessment. ...

" In indicating that an investment allowance might not be allowed for such a policy, CRA stated: [T]he only assets issued by a corporation that is a financial institution that qualify for the investment allowance … are a share of the financial institution or a long-term debt. ...

In this regard, the Directorate stated: [T]he provisions of paragraph 40(2)(g)(ii), that deem a loss on the disposition of certain debt obligations to be nil, do not apply since the … debt obligation was interest-bearing, as the taxpayer was subrogated by the financial institution as to the interest-bearing mortgage ...

The Directorate, in noting that “[i]t is possible that the person paying salary or wages is not the employer,” repeated the statement in Mollenhauer “that subsection 153(1) … does not speak of whether persons doing the paying are employers or not,” and went on to find that the Persons likely were employees of Cco, so that the charges from Bco for their salaries likely could be included in the “cost of labour” of Cco under Reg. 5202. ...

17 February 2004 Internal T.I. 2003-0046981I7 F- Paragraphe 98(5) de la Loi-- summary under Subsection 98(5) Summary Under Tax Topics- Income Tax Act- Section 98- Subsection 98(5) s. 98(5) inapplicable on an amalgamation of the members The Directorate essentially repeated the position stated shortly thereafter in 2003-0050041E5 F, namely: [S]ubsection 98(5) is not applicable … where the members' interests are sold simultaneously to a corporation, since the corporation was not a member of the partnership immediately before the partnership ceased to exist. ...

In finding that this amending agreement did not have retroactive effect, so that Monsieur could not amend his prior returns to claim the s. 118(1)(b) deduction for the other child (as was previously prohibited pursuant to s. 118(5) by virtue of him having paid support for that child), the Directorate stated: …. ...

. … Paragraph 9 of Interpretation Bulletin IT-464R states that the time of disposition of a leasehold interest by a tenant includes, inter alia, the time of expiration of a lease or the time of cancellation of a lease if it is prior to the expiration date. ...

In order to do so, the taxpayer will have to provide supporting documentation or acceptable evidence that clearly establishes that an amount included in the net worth was actually paid by the taxpayer for an item that is deductible in computing the taxpayer's income from the illegal activity …. ...