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The Directorate indicated that FA4 appeared to have two separate businesses- a debt portfolio business, and a business of providing services to other foreign affiliates in the group – given inter alia that its services were mostly to other foreign affiliates (in contrast to the arm’s length customers of the debt portfolio business) and thus not principally services rendered to FA4’s own debt portfolio business. ...

16 April 2024 Internal T.I. 2023-0964831I7- Guaranteed payments to non-resident athletes-- summary under Subparagraph 115(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(i) guaranteed salary payments received by a US-resident member of a Canadian team while not in Canada were not taxable in Canada A resident of the US, who had entered into a 6-year employment contract (covering years 20X1 to 20X6) with a Canadian team, suffered a serious injury in the 20X3 season but, pursuant to a guaranteed payment clause in his contract, continued to receive full salary for the remaining contract term notwithstanding that he ceased playing for that team – and was released by that team in 20X4 and hired by a US team in 20X5. ...

. … In such case, the CRA would generally rely on the relevant foreign corporate or company law and the details of the plan of conversion to determine whether there is a continuity of existence on the Conversion. ...

. … [T]he term “maintained” must be interpreted as meaning “incurred expenses in respect of the self-contained domestic establishment (residence)”. ...

. – but further provided that in special justifiable circumstances, reimbursement of the following allowances could be authorized: a) a compensatory allowance for the self-moving of furniture, equal to 50% of the estimate of a moving firm, b) a compensatory allowance for the self-sale of the residence, established at 3% of the sale price, and c) in the event that the employee waived the employee’s right to the reimbursement of moving expenses, a compensatory allowance for additional moving expenses equaling 50% of the following: certain related expenses, real estate agent fees equivalent to 6% of the residence’s municipal evaluation, notary fees of $850 and the amount of a moving company estimate. ...

If the facts show that it is only the time of payment that is not precisely established, but that there is no uncertainty as to the payment of the amount … it could then be a future obligation to pay and not a contingent obligation. ...

However, before concluding that “a snowmobile is … not a motor vehicle since it is not designed or equipped for use on public roads,” it stated: The first expression used, “designed or adapted” should, in our view, be used not in the sense of “capacity” but rather in the sense of “having or being organized for a specific use.” ...

. … In Mr. A's case, it is reasonable to assume that the assumption of responsibility for the mortgage debt obligations was intended to generate income by protecting his investment. ...

. … [S]ince the necessity to effect the circular calculation…is well known, we believe that a reasonable and prudent person would have effected the circular calculation in order to report (in the income tax return filed) the correct figures to the Minister. ...

. … Since a portion of the lump sum received in respect of the Medical Plan was received before 2012, that portion does not have to be included in the computation of the Objectors’ income. ...