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The Directorate stated: [P]aragraph 84.1(1)(a) would not apply to the disposition by each of Brother 1 and Brother 2 of the Class A shares … of Amalco 1 or Amalco 2 … to reduce the ACB in respect of the Class B preferred shares … of Holdco 5 and Holdco 6 received as consideration. … [F]or the purposes of paragraph 84.1(1)(a), the ACB to Brother 1 or Brother 2 … of the Class A shares of Amalco 1 or Amalco 2, as the case may be, would technically be deemed to be approximately $XXXXXXX. This is because there would technically be no amount each of which is an amount determined after 1984 under subparagraph 40(1)(a)(i) in respect of a previous disposition of a Class A share of the capital stock of Amalco 1 or Amalco 2, as the case may be, or to an earlier disposition of a share for which that Class A share of the capital stock of Amalco 1 or Amalco 2 would have been substituted (i.e., a Class A share of the capital stock of Holdco 3 or Holdco 4, as the case may be, or, having regard to subsection 248(5), a Class A share of the capital stock of Holdco 1 or Holdco 2, or any of the 149 Class A shares of the capital stock of Opco referred to in (1)(c) above). … [However] in the event that taxpayers apply for advance rulings in respect of a series of proposed transactions similar to the one described above …[we] would … refer such a case to the General Anti-Avoidance Rule ("GAAR") Committee. ...

However, … subsection 246(1) may apply … if it were established that Corporation C conferred the benefit for the personal use of the Aircraft.” ... A’s income … if it was a payment made directly to Mr. A, since Mr. A is not a shareholder of Corporation E. ... A … However, in … Masicotte the judge concluded that subsection 246(1) could apply when a corporation confers a benefit on an indirect shareholder. ...

. … The normal reassessment period thus commenced…from the assessment…in 2009. … The conditions for the application of the subparagraph [152(4)(a)(i)] do not require the making of a return by the taxpayer in order to accord the right to the Minister to issue an assessment outside the normal reassessment period. … [W]here a taxpayer has been assessed under subsection 152(7) after having received a demand…under 150(2), the taxpayer has made a misrepresentation ["présentation erronée des faits"] by virtue of wilful default ["omission volontaire"]. … Thus…the Minister can reassess respecting the 2008 year…in order to take into account the new information…. ...

As for the missions covered for the purposes of subclause 110(1)(f)(v)(v)(A)(II), they are provided for in [Reg.] 7500 …. ... Furthermore …, it would appear that the … operations in which the taxpayer participated are missions referred to for the purposes of subclause 110(1)(f)(v)(A)(A)(II). … [T]he question of whether someone is a member of the Canadian Forces must be resolved in light of the relevant provisions of the National Defence Act. ...

Before finding that these premiums were not deductible in computing his income from a business, CRA stated: Where an insurance broker, who is self-employed, receives a commission from the sale of a life insurance policy owned by him …CRA … is generally of the opinion that this income does not have to be included in the calculation of the broker's business income as long as the broker is required to pay the premiums relating to the policy. ... Notwithstanding our position stated above, we are of the view that … the commission received or receivable could be considered taxable … where the amount of the commission is substantial. … Thus, because of the amounts of commissions received, it is likely that they will have to be included in the broker's income for the year in which they are received. ...

Therefore …the employee was required to include in her employment income … under subsections 6(3) and 5(1), all amounts [so] received …. …[I]f the employee reimburses in 2010 the balance owing … in respect of the deferred salary leave plan, she could take the deduction under paragraph 8(1)(n) in computing her income for 2010. … [S]uch a deduction would be limited to the amount advanced and paid during the period of deferred salary leave, which had already been included in her income. ...

On the facts …, we are of the opinion that the Corporation was entitled to receive the life insurance proceeds in … the year of Individual's death. The capital sum insured … can therefore be considered to be an amount of principal owed to the Corporation … on which the Court awarded interest under article 1619 C.C.Q. ...

CRA stated: [L]og hauling services performed by a subcontractor from the point of harvest to the point of delivery of the logs to a processing plant (sawmill, pulp mill, plywood mill or other similar log processing location), can constitute an activity of logging for purposes of the definition of qualified property in subsection 127(9) and paragraph 4600(2)(f) … based, inter alia, on Lor-Wes …. ... Finally, a logging truck as described in paragraph 4600(2)(f) … could be considered to have been acquired for use in logging … if it were acquired by a subcontractor with the intention of using it for log hauling services to sawmills, pulp mills or other processing sites on behalf of a number of wood producers who are either farmers who own woodlots or simply other persons who own woodlots for whom income from the sale of wood is not the primary source of income. ...

. … [T]he term "group … insurance plan”… includes, in particular, accidental death and dismemberment insurance plans. Therefore, if the Insurance Coverage is a group insurance plan, we are of the view that the total amounts paid by the Employer in respect of an employee during a year of Insurance Coverage is to be included in computing the employee's income from an office or employment under paragraph 6(1)(e.1). … [T]hat the Insurance Coverage primarily benefits the Employer … is not relevant for the purposes of paragraph 6(1)(e.1). ...

Regarding the resulting disposition, the Directorate stated: In the case of property forfeited by statute … the definitions of "disposition" and "proceeds of disposition" … are broad enough to include the disposition of the property at the time it is forfeited, for proceeds of disposition that are nil…. ... [Here] there was a disposition of the seized equipment … at the time the court confiscated the property pursuant to section 16 of the Controlled Drugs and Substances Act. … [T]ax treatment of such equipment dispositions should be in accordance with the Act regardless of whether they are derived from illegal activity. ...