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The CRA accepts that, pursuant to the tax relief measure described in paragraph 7 of Article XXI … a gift made by a Canadian resident to a U.S. 501(c)(3) organization will be an eligible gift for purposes of the deduction in computing taxable income under section 110.1 …. or a non-refundable tax credit … under section 118.1 … subject to the income limitations, described in those sections, from U.S. sources. ... [S]ince subsections 149.1(2), (3) and (4) … govern the revocation of a charity’s registered status, and not the imposition of taxes, the Canada-U.S. ... Accordingly … Article XXI[(7)] of the Canada-U.S. Treaty does not deem a U.S. 501(c)(3) organization to be a qualified donee, for purposes of subsections 149.1(2), (3) and (4) …. ...

. … [T]he discharge from bankruptcy is not retroactive to the time the individual was declared bankrupt but … is effective from the date the proposal is approved by the court. … Although section 128 does not recognize proposals filed under the BIA, the discharge from bankruptcy [in] 2005 does not invalidate the filing and assessment of pre- and post-bankruptcy tax returns made prior to the date of discharge. … [T]he individual was bankrupt in the 2003 … 2004 … and the 2005 taxation year[s]. ... Since the approval of the proposal by the Court and the discharge of the individual's bankruptcy does not amount to an unconditional discharge under paragraph 128(2)(g) … we do not believe that this paragraph deems the unused portion of his tuition tax credits to be nil. Consequently, the individual may carry forward the unused portion of his or her tuition tax credits at the end of the 2005 taxation year … to the 2006 taxation year pursuant to section 118.61. ...

In finding that the condition in s. 22, that there still be outstanding accounts receivable that were required to be included in computing Amalco’s income in respect of that business, appeared to not be met, CRA stated: The only inclusion in income [of] Amalco … in respect of accounts receivable of Predecessor 1 is under 12(1)(d) and it includes in its income a reserve (there is no presumption that the underlying receivable was included by Amalco in its income). Respecting the requirement that Amalco have carried on the Business, the Directorate stated: [Y]ou express the view that because Amalco sold the assets used in the Businesses … minutes after the amalgamation, it did not “carry on the business” of Predecessor 1, hence the election under section 22 was not valid. … That view might arguably be consistent with … Gillen …. However, the Directorate concluded that the election was satisfied (on the basis that the other conditions of s. 22 were satisfied and the business was continued) stating: Provided there is no disruption in the continued operation of the business … the context and purpose of section 22 are satisfied where a corporation resulting from an amalgamation that is governed by section 87 or its predecessor have included receivables from that business in their income and have used property in carrying on that business. ...

14 October 2011 Internal T.I. 2011-0410781I7 F- Repas fournis gratuitement-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) benefit from free meals delivered on-site Respecting a proposal that employees would receive a catered meal service during their shifts, CRA stated: [T]o the extent … the provision of free meals … primarily benefits the employees and not primarily their employer, … the value of that benefit should be included in computing the income of those employees. ...

A taxable capital gain from the disposition of a "Canadian resource property" is therefore not included pursuant to subparagraph 115(1)(a)(iii) …. [Furthermore] … it is highly doubtful that the Right can be considered real property …. Article 900 of the Civil Code of Québec, which states that "fruits and other products of the soil may be considered to be movables … when they are the object of an act of alienation,” leads us to believe that the Right would not constitute immovable property but rather movable property. ...

The Directorate stated: [P]aragraph 13(34)(a) states … that where a taxpayer carries on a particular business, there is deemed to be a single goodwill in respect of the particular business. … [T]he goodwill and the customer relationship … constitute a single property, being the goodwill in respect of the Taxpayer’s business. … 2017-0709141C6 … confirmed that a designation pursuant to paragraph 111(4)(e) can be made with respect to internally generated goodwill. ...

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After referring to s. 123.7 et seq. pf the Quebec Companies Act (providing inter alia that “A company is bound by any deed performed in its interest before its constitution provided it ratifies the deed within 90 days after its constitution”), the Directorate stated: Where there is no legislation similar to the Quebec Companies Act, the Canada Revenue Agency ("CRA") will normally accept newly incorporated corporation recognizing transactions prior to its incorporation if the … conditions, as set out in … IT-454 [para. 3] are met …. ... B intended, when entering into the agreements with these two parties, to form Company D nor that the latter was the entity that was to deduct the fees. … With respect to the fees paid to Advisor B, the situation is, in our view, somewhat different because, based on the facts you have provided, Corporation D was formed as soon as the mandate was granted to Advisor B. ...

9 April 2003 Internal T.I. 2003-0001597 F- FRAIS ACCESSOIRES-- summary under Subsection 18(3.1) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(3.1) application of s. 18(3.1) to work on a rental property The Directorate indicated that s. 18(3.1) applied to the following categories of expenditures if work on a rental building constituted a renovation rather than repair and maintenance work giving rise to currently deductible expenses: Property taxes during the renovation period that are related to the ownership of the land subjacent to the building …. … [P]roperty taxes related to the ownership of land that meets the following conditions: 1. it is contiguous to the land subjacent to the building 2. it is used, or intended to be used, as a parking lot, driveway, yard or garden or for a similar purpose 3. it is necessary for the present or proposed use of the building. … Interest charges on the portion of the mortgage obtained to renovate the building that relates to the renovation period … [and] interest charges on the portion of the mortgage used to acquire the land described above that relates to the renovation period. Insurance and utility costs … only to the extent that they relate to the renovation. For example, this would be the case for additional insurance costs that the taxpayer had to incur to cover a risk related to the renovation. … Legal costs related to obtaining financing for the renovation … [and] the legal costs of acquiring the building and land …. ...

Furthermore …., under civil and common law, a partnership … is simply the relationship that exists between persons or partners who carry on a business in common for profit. ... We refer you to … Klein [which] stated: …[T]he partnership itself does not have the capacity to be indebted. The debt of the partnership is owed by the partners …. ...