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In this regard, CRA stated: Where an employer does not reimburse an employee for employment-related electricity costs paid by the employee and the employment-related electricity costs can be established, the costs may be deducted by the employee as motor vehicle travel expenses if all of the conditions in paragraph 8(1)(h.1) … are met …: was normally required to carry out his or her employment duties away from the employer’s place of business (or in different places); was required by the contract of employment to pay such expenses; and did not receive a non-taxable allowance or reimbursement in respect of the motor vehicle expenses. …[S]ubsection 8(10) … requires the employee to obtain a completed and signed Form T2200 … ...

. … [P]aragraph [146.1(6.1)(b)] could cause the years of existence of the transferring RESP to be taken into account in determining when "accumulated income payments" may be made under the receiving RESP pursuant to 146.1(2)(d.1). If applicable, those years would also be taken into account in determining the maximum duration of the receiving RESP provided in paragraph 146.1(2)(i) and determining the period during which contributions may be made into the receiving RESP pursuant to paragraph 146.1(2)(h). … However, depending on the circumstances, a transfer between RESPs could result in the subscriber of the transferring RESP, the receiving RESP, or both, having to pay tax under subsection 204.91(1) … [but not in] the situation described …. ...

. … [E]xpenditures in respect of research in determining economic viability may be considered to be on income account …. ... [If] … the expenditure brings into existence an asset or advantage that has an enduring benefit... it is denied current deduction …. ...

5 May 2021 IFA Roundtable Q. 4, 2021-0887601C6- 2021 IFA Q4- section 247 Post Cameco-- summary under Paragraph 247(2)(a) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2)- Paragraph 247(2)(a) Cameco may limit the use of s. 247(2)(d) recharacterization – and acknowledges that s. 247(2)(c) must take into account a relationship’s circumstances Regarding the CRA response to the TCC and FCA decisions in Cameco, CRA stated “that these decisions may limit situations where the re-characterization provision in paragraphs 247(2)(b) and (d) could be applied … [h]owever, the CRA will continue to consider the application of the re-characterization provision where appropriate.” CRA further stated: The CRA will continue to administer … 247(2)(a) and (c) in a manner consistent with the guidance … [in] General Electric [para. 54]: “…The task in any given case is to ascertain the price that would have been paid in the same circumstances if the parties had been dealing at arm’s length. ...

7 October 2021 APFF Roundtable Q. 14, 2021-0901041C6 F- Meaning of Any consideration received by Donee-- summary under Paragraph 118.1(13)(c) Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(13)- Paragraph 118.1(13)(c) “consideration … received” in s. 118.1(13)(c) includes a s. 84(3) deemed dividend Under s. 118.1(13)(c), where a qualified donee that disposes of non-qualifying securities (“NQS”) that were gifted to it, the amount of the original gift will be deemed in some circumstances to equal the fair market value of the “consideration” received by the donee for that subsequent disposition. ... CRA responded: [G]enerally speaking, and in the absence of any indication to the contrary … the notion of "consideration" is broad enough to encompass any amount, good or service received upon the disposition of property. The CRA is of the view that the word "consideration" in the phrase "fair market value of any consideration … received by the donee for the disposition … of the security" in paragraph 118.1(13)(c) must be given the broad meaning generally accepted in the jurisprudence. ...

Does the requirement of s. 144.1(2)(f) (dating from before the introduction of the Alternative Condition) – that the rights under the trust of each key employee are not more advantageous than the rights of a class of beneficiaries described in s. 144.1(2)(e)- apply only where the Beneficiary Condition is relied upon (so that where the Alternative Condition is met, the plan is not required to satisfy s. 144.1(2)(f))? CRA responded: The condition in paragraph 144.1(2)(f) … should only apply where a trust meets the condition in subparagraph 144.1(2)(e)(i) … and does not apply to a trust that meets the condition in subparagraph 144.1(2)(e)(ii) … ...

CRA responded: [O]ur long standing position [is] that a shareholder benefit arises under subsection 15(1) … when a corporation pays the life insurance premiums on a policy pursuant to which the shareholder or a person related to that shareholder is the beneficiary of the policy. The amount of the benefit to be included in computing the shareholder’s income in a given taxation year is usually equal to the amount of the insurance premiums paid by the corporation for that year. … Accordingly, given that a segregated fund policy is, by definition, a life insurance policy, we cannot confirm that no benefit arises in the described situation …. The question of whether a benefit under subsection 15(1) … has been conferred is generally one of fact to be determined on a case-by-case basis. ...

CRA stated: According to paragraph 6 of … IT-293R, a debt or obligation is settled or extinguished when the obligation to pay ceases to exist, and payment, cancellation, set-off, substitution of debtors and release are among the means of settlement. … Furthermore … Richer indicat[ed] that "in the context of section 80, the word 'settle' connotes a final and legally binding resolution that terminates or reduces the debtor’s obligations” …. ...

Would this satisfy the condition in s. 146.01(1) – regular eligible amount- para. ... In responding negatively, CRA stated: [O]nly after the individual has actually contributed amounts to the individual’s RRSP, no later than the first 60 days of the year, and indicated the total amount contributed as an HBP repayment for the previous taxation year on the prescribed form … will the individual be able to declare that the individual’s HBP balance is nil at the beginning of the calendar year. … [W]hen the individual makes a withdrawal from the individual’s RRSP on January 20, 2022, his HBP balance at the beginning of the year 2022 for the purposes of the definition of "regular eligible amount" will [still] be $5,000 … because no HBP repayments have yet been made and reported on the prescribed form. ...

(c) of the definition of “excluded entity” in s. 18.2 is that “all or substantially all of the businesses … and undertakings and activities of the taxpayer are … carried on in Canada.” ... In this scenario – where Canada maintains full ability to tax – are the businesses, undertakings and activities of B Co carried on in Canada? ...