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(e)(iii) exclusion applied, CRA stated: [T]he wording of the exclusion … allow[s], inter alia, an employee's own vehicle that is used in the course of employment under the conditions set out in that subparagraph, and for which the employee's expenses are not reimbursed by the employee's employer, to be excluded from the definition of automobile …. [T]he exception in subparagraph (e)(iii) … may even apply to a self-employed person who primarily uses the individual’s vehicle at a location described in subparagraphs 6(6)(a)(i) or (ii) …. ...

., 1996 J.Q. no. 5103 … established that support and custody judgments lose all effect when the parents resume living together … [and] that these judgments would not take effect if the parents subsequently separated again. … Since the amounts were paid under a new agreement, which was only a verbal agreement between the parties, that arose following the second separation, the amounts paid by Monsieur do not meet the definition of "support amount" in subsection 56.1(4) …. ...

. … [I]f the employee did not intend at the time the salary deferral arrangement was created to return to work after the leave for a period at least equal to the duration of the leave, the deferred amounts must be included in the employee's income in the taxation year in which they were deferred. … In addition, if the employee decides during the course of the arrangement to retire at the end of the leave and does not return to work as initially provided for in the arrangement, the deferred amounts will be taxed in the year in which it is known that the above-described condition will not be satisfied. ... The Directorate responded: [I]f, prior to the leave, an employee was working full-time, then upon the employee’s return to work, the employee must once again work full-time within the employer's business …. If the employee was working part-time before the leave, the employee may return to work part-time or on a busier schedule …. ...

16 April 2024 Internal T.I. 2023-0998991I7 F- Qualification fiscale de certaines sommes-- summary under Paragraph 56(1)(n) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(n) amount per week of training in short-term program leading to a skills training certificate was a bursary/ amount paid upon graduation was a bursary or a prize Regarding the tax treatment of amounts paid as part of a Construction Sector Training Initiative, namely (a) $750 per week of training, paid every two weeks to an individual who registered between October 30 and December 15, 2023 in a short-term study program leading to a skills training certificate; and a "bourse de perseverance [persistence bursary]" in the amount of $9,000 to $15,000 paid to an individual upon graduation if certain eligibility criteria were satisfied, the Directorate stated: [T]he … $750 per week of training that will be paid to an individual enrolled in a program of study leading to a skills training certificate … qualifies as a bursary since it is paid so that the individual can continue the individual’s studies. … [T]he "bourse de persévérance" … qualifies as a bursary if it is paid for the pursuit of studies, whereas it qualifies as a prize for achievement in a field of endeavour ordinarily carried on if it is paid in recognition of obtaining a diploma. ...

4 May 1995 Internal T.I. 9509607- PRINCIPAL RESIDENCE EXEMPTION AND CAPTIAL GAINS-- summary under Principal Residence Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence Detailed discussion of whether the principal residence exemption is available where a client purchases a house located on a lot under ½ hectare in size and later, after obtaining approval for a subdivision, either sells the additional lot, or builds a house on the additional lot and sells it; and in a situation where the client buys a house located on a ¼ acre and also buys the adjacent ¼ acre lot, either at the same or at a subsequent time. ...

18 May 2000 Internal T.I. 2000-0006037 F- FRAIS D'ACQUISITION-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing commissions directly related to the acquisition of a life insurance policy are generally deductible in the year incurred CCRA indicated that “the matching principle mentioned in … IT-417R2 as well as the Agency's comments on the Canderel and Toronto College decisions set out in Income Tax Technical News No. 16 [and] … F9913160 … do not apply to acquisition expenses incurred by an insurer” (i.e., life insurance policy acquisition expenses, including commissions directly related to the acquisition of the policy) but indicated that generally, those expenses are deductible in the year in which they are incurred. ...

. … [W]hen the time is right, Aco realizes its investments and profits from them. … [T]hese facts alone demonstrate that generally Aco's share acquisitions would be made in the ordinary course of business of the corporation it operates. … … Gco was only formed to be used in the process of disposing of Aco's interest (via XXXXXXXXXX) in the capital stock of Bco. ... To the extent that, based on such an analysis, it was demonstrated that Aco's investment in Bco was not exceptional in relation to its other investments, we would be of the view that the shares of the capital stock of Gco would have been acquired in the ordinary course of the business carried on by Aco and/or XXXXXXXXXX and that subsection 112(2.1) would apply …. ...

Finally, although the relative value of labour in relation to the value of the total property suggests that labour is a capital expenditure … this ratio is not necessarily decisive …. [T]he fact that work was not carried out earlier does not change the nature of the work when it is finished, regardless of its total cost. … In Méthé [86 DTC 1364], the TCC stated that the increase in rental income was the most conclusive evidence that the work done by the taxpayer resulted in a nearly new building and not the same original building. … Thus, the increase in gross rental revenues in this case, for the years following the work, will be a factor that will allow us to conclude whether the expenses incurred by the taxpayers were current or capital in nature. ...

. … In addition, since employees reside in Ontario, the compensation paid must not exceed the compensation payable under Ontario's Workplace Safety and Insurance Act. If the employer guarantees the full amount of wages or a percentage that is greater than the percentage payable under Ontario's workers' compensation legislation, the amounts received by the employee in excess of the compensation payable under the provincial legislation are fully taxable. … [B]enefits received by an employee pursuant to an employer's obligation under the Code are considered to be received under a federal workers' compensation statute for the purposes of paragraph 56(1)(v) and subparagraph 110(1)(f)(ii). … Compensation received under a workers' compensation act of Canada or of a province in respect of injury, disability or death must be included in computing the employee's income pursuant to paragraph 56(1)(v). ... No withholding under subsection 153(1) is required …. [T]he use of the administrative services of an intermediary does not change the above tax consequences. ...

. … Any notification sent to the partnership in this circumstance would merely be an acknowledgement that the information has been received and recorded. However, the Minister may use the information contained in the amended T5013 to reassess one or more of the partners provided that the taxation year of the particular partner or partners is not statute-barred. … [T]he Minister may reassess the return of income of a member of a partnership without making a determination of the partnership under subsection 152(1.4) of the Act provided the partner’s particular taxation year is not statute-barred. … Accordingly … the Minister had the authority to issue the reassessment for Partner 2. ...