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After observing that “[p]rovincial income tax is not deductible … since … [it] is not an expense incurred for the purpose of gaining or producing income but rather is an expense incurred because income was earned,” CRA stated: Capital tax is not a tax that is calculated on the income of a business but rather a tax calculated on the paid-up capital of the corporation. ... The 1991Budget of the Department of Finance is consistent with this approach. … Interest on capital tax will be deductible if the capital tax is deductible by virtue of section 9. ...

The Directorate responded: [Per] E 2002-0121825 … if the taxpayer provides a written certification from the taxpayer's physician that, in his or her opinion, on the basis of the taxpayer's medical condition, the taxpayer is unable to obtain substantially equivalent medical treatment … the travel expenses would be eligible. … This certificate should state the reasons why the physician is of the opinion that there are no adequate and appropriate medical services in the venue where the patient resides. ...

.-- summary under Subsection 126(3) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(3) organization that brought together states, government agencies and non-governmental organizations did not qualify as an intergovernmental organization In finding that an organization did not qualify under s. 2, the Directorate stated: Under section 2 … an "international organization" means an intergovernmental organization of which two or more states are members. ... It therefore appears to us that XXXXXXXXXX is not an intergovernmental organization, but rather a non-governmental organization. … Consequently, income from employment with XXXXXXXXXX cannot give rise to a tax credit under subsection 126(3) …. ...

The Directorate stated: Where a building constitutes depreciable property … [Reg. 1102(2)] has the effect of splitting the property into two for the purposes of the Act, namely the land and the building. In the case of a cottage that is a PUP, we are of the view that the land and the building will remain one and the same property for tax purposes if they constitute one and the same property for legal purposes. … [Here] the taxpayer will realize a capital gain of $15,000 on the disposition …. ...

After finding that he was not able to deduct the legal fees incurred by him in negotiations with the tax authorities, the Directorate went on to state: … E9930565, F9809347 and E9608715 … discussed the tax treatment of the debt paid by directors in discharge of their joint and several liability with a corporation … [and concluded] that the debt arising to the directors from their obligation had not been acquired with a view to earning income from a business or property. ...

After the Excise and GST/HST Rulings Directorate queried the view in 2014-0530691E5 that: a professional status would generally have to be acknowledged in the statute itself to satisfy the “recognized by statute” condition in subparagraph 8(1)(i)(i) …. the Income Tax Rulings Directorate changed course and concluded: [F]or purposes of the meaning of the phrase “professional status recognized by statute” … applying a textual, contextual and purposive analysis, a “professional status” can be “recognized by a statute” for purposes of subparagraph 8(1)(i)(i) … even if it is only recognized in the supporting regulations of an act. ...

On the sale, it realized a capital gain of $50,000 and a terminal loss of $60,000 – except that, pursuant to s. 13(21.1), the capital gain became nil and the terminal loss became $10,000, so that pursuant to s. 13(21.1), the deemed proceeds of disposition of the building were $250,000. The Directorate stated: [T]he expression “that would otherwise be the transferor’s proceeds of disposition of the transferred property” used in paragraph 13(21.2)(b) means the proceeds of disposition of the building determined having regard to subsection 13(21.1) … [i.e.] $250,000 … [so that] the vendor would be deemed to own a property with a capital cost of $10,000. ...

14 June 2000 Internal T.I. 2000-0021237 F- VALEUR RELATIVE D'UN JUGEMENT-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) Agency not bound to accept an amended return based on a favourable informal TCC decision re similar facts In finding that the Agency was not bound to amend a return based on a favourable Informal Procedure judgment rendered to a taxpayer in similar circumstances, it stated: The Agency … does not automatically agree to process an amended tax return on the basis that another taxpayer has won their case in court. ... Furthermore, the Agency cannot be forced to agree to process an amended return reflecting a judgment handed down by the Tax Court of Canada under the Informal Procedure because such a judgment does not constitute binding jurisprudence according to … section 18.28 of the Tax Court of Canada Act …. ...

. … Example 2 … Mr. A is present in Canada for 212 days in 2015, and the income of the partnership derived from his services is more than 50% of the gross active business revenue of the partnership ($200,000 / $350,000 = 57.14%) during those 212 days. ...

CRA further indicated that “because both the father and the mother have an obligation to support their children … where court costs have been incurred to increase child support or to make child support non-taxable, the CRA accepts that those costs are deductible in computing the taxpayer's income.” ... [W]ith respect to the taxpayer's claim for increased support from her former spouse for the benefit of the son born of the marriage … the underlying legal expenses are [not] deductible from the taxpayer's income. Although the jurisprudence indicates that the right to such support is not extinguished by the dissolution of the marriage and that the related legal fees are current in nature … the amounts claimed by the taxpayer [do not] truly constitute support, since the taxpayer has no discretion as to the use of the funds under subsection 56.1(1) and the definition of "support" in subsection 56.1(4). … [T]he fact that the legal proceedings are currently suspended can [not] affect the deductibility of the expenses in question. ...