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. … [T]he Taxpayer would need to demonstrate that the ship owner is operating the ship under the Taxpayer’s direction and not, in effect, under the direction of the Related Party Customers. ...

. … The CRA's longstanding position is instead to reduce the safe income on hand by every dollar of expenses that contributed to the loss sustained by the corporation on the grounds that such income is no longer on hand to contribute to the unrealized capital gain on a share. ...

. … In the case where each of the co-owners has the exclusive right to live in his or her own unit, the value of their undivided share must take into account at the same time the exercise by each of them of the exclusive use and enjoyment of their unit, which necessarily includes the right to the use of the common parts of the building, and the prohibition on the use of the unit occupied by the other co-owner. ...

. … [W]here a trustee or an insurance company pays benefits to an employee from a wage-loss replacement plan over which the employer does not exercise control, or where the employer does not determine eligibility for benefits, the trustee or insurance company is required to report the benefit amounts on a T4A information slip. ...

1 April 2010 Internal T.I. 2009-0352611I7 F- Redressement après le délai de prescription-- summary under Subparagraph 152(4)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(i) statement of incorrect income amount for spouse for s. 118(1)(a) credit purposes is a misrepresentation – but CRA must establish that prudent person would not have so erred Where a taxpayer claimed the married or common-law partnership tax credit (the "Tax Credit") and, after the taxpayer’s spouse was assessed beyond the normal reassessment period to add unreported income, can CRA also reassess the taxpayer beyond the normal reassessment period? ...

The Directorate stated: [C]adastral lots are considered, for the purposes of the Act, to be separate real property …. ...

. … [T]he only significance of the fact that the penalty is assessable in respect of Year X and not Year X+7 is… the de minimis rule in paragraph 247(3)(b)…. ...

However, recognizing an upstream loan would result in double counting because the assets acquired by the parent out of the proceeds thereof would already be counted for purposes of the tests – so that the loan’s value decreases the relevant FMV of the shares of the particular wholly-owned subsidiary. ...

The Directorate confirmed the TSO approach, which was to designate pursuant to s. 80(16) the maximum amounts permitted under ss. 80(7) and (11), so that the forgiven amount would be applied first against the balance of the non-capital loss, second as to reduce ¾ of the cumulative eligible capital and third, to reduce the adjusted cost base of the related corporation shares under s. 80(11), resulting in an amount being deemed to be a capital gain from the disposition of capital property under s. 80(12). ...