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. … Finally … Ahmad … held that pre-judgment interest was not taxable because no amount was owed to the taxpayer before the judgment was rendered. ...

The Directorate stated: [B]ased on the terms of the Payment Agreements … Canco agrees to make advanced payments to NR that are set off or deducted from the amount due by Canco to NR required under the Initial Contract. ... As such, the nature of the payments is different from [those] … in … 2008-29716 …. ... Accordingly … the advance payments made by Canco to NR under the Payment Agreements are subject to the withholding requirements of section 105 …. ...

Repairs or Running Expense expenditure on Canadian film production can be current expense if it is only of short-term use Is whether an expenditure on a "Canadian film or video production” ("CFVP") is a current expense, or a capital expenditure on depreciable property, determined in accordance with the criteria set out in 9722707, which states: Generally, the cost of preparing a tape will normally be considered a current expenditure where the tape is only of short-term use, either because it is merely of current topical interest or because it is intended to be shown only once (…) In these latter situations, the material is normally retained on the tape for record purposes only. ... CRA responded: The criteria set out in that paragraph may still be used …. … In addition … a likelihood of a particular production generating revenues other than those provided for in the original broadcast contract, for example, from the sale of DVDs, the awarding of contracts for broadcasting on the Internet, on specialty channels or in territories not covered by the original broadcast contract, can also be taken into consideration in determining whether the costs related to a production should be considered as capital expenditures in respect of depreciable property. … [W]here the broadcast contract covers a period of several years, under which the broadcaster has the right to broadcast the production several times during that period, this would be an argument to support that the costs associated with the production provide a lasting benefit to the producer. ...

" While IT-283R2 has been archived … the above statement … is still valid. … In regard to the CCA class, paragraph 8 of IT-472 [states]: " … The Department considers the following property to be so included in Class 8:... ...

For the latter amount to be accepted, it must be reasonable in amount, as to which the Directorate stated: Although the maximum amount provided for in paragraph 53(2)(e) … is $20,000, it is possible that, in similar cases, the Tribunal may award only a relatively small amount compared to this maximum. …[W]e have … asked … for information concerning … human rights at the provincial level. We found that … human rights tribunals in several provinces (some of which had a maximum limit for general damages of less than $20,000 and some of which had no maximum limit at all) generally only awarded amounts below the maximum limit for general damages. ...

The Directorate stated: # 2007-022925 and # 2004-0107761E5 … stat[ed] that in situations similar to those of Ms. ...

25 February 2002 Internal T.I. 2001-0114167 F- DOMMAGES- DISCRIMINATION-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) awards by human rights tribunals for pain and suffering re wrongful termination often are under $5,000 Regarding what portion a settlement of a claim made under the Canadian Human Rights Act should be treated as compensation for pain and suffering, CCRA indicated that it had not examined the awards pattern of the federal Human Rights Tribunal in this regard, but noted: Although the maximum amount provided for in paragraph 53(2)(e) … is $20,000, it is possible that, in similar cases, the Tribunal may award only a relatively small amount compared to this maximum. …[W]e have … asked … for information concerning … human rights at the provincial level. We found that … human rights tribunals in several provinces (some of which had a maximum limit for general damages of less than $20,000 and some of which had no maximum limit at all) generally only awarded amounts below the maximum limit for general damages. ...

James … 66 DTC 5241 …. Subsection 164(4.1) … does not … prevent a taxpayer from changing the computation of the taxpayer’s loss carryforward from a previous year … consequent on a favourable decision received by another taxpayer. ...

In finding that the penalty could qualify as a “child care expense,” the Directorate stated: [T]he expression “expense incurred … for the purpose of providing … for an eligible child … child care services …” is sufficiently flexible to include contract termination fees where such fees were provided for in the initial agreement between an individual and a daycare centre that set out the commitments and obligations of each party. ...

. … [W]e have assumed that the rental income is property income to the non-resident person rather than business income (in which case the rental income would not be subject to Part XIII tax but rather to Part I tax). … [T]he services provided by [the property manager] o the lessees do not appear to be sufficiently important to characterize the rents as business income (see … IT-434R and … Walsh … 65 DTC 5293 (Ex. ...