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The Directorate went on to note that “Son also held contingent beneficial interests in the remaining … Estate [assets], which would only be realized if the other Children die without issue surviving” and that: …[I]t is unlikely that the FMV of Son’s contingent beneficial interests at the Time could result in him being considered a “majority-interest beneficiary” of Father’s Estate. … Accordingly, it is unlikely that the FMV of the total of Son’s respective income or capital interests in Father’s Estate could reasonably be considered to be greater than 50% of the FMV of all of the income or capital interests in Father’s Estate …. ...

CRA responded: [W]here salary and wages are paid to an eligible employee and returned to the eligible employer with a corresponding increase or credit to a due to shareholder loan account or other shareholder loan account, we consider such salary or wages would not be eligible remuneration … pursuant to paragraph (c) …. Similarly, salary and wages paid but returned to the corporation by the shareholder/employee as a capital contribution or as an amount re-loaned to the corporation would not be considered eligible remuneration …. ...

.) – or pays an allowance based on a kilometric rate for use of their private vehicles, as well as a meal allowance upon presentation of receipts. Before concluding that the kilometrice allowances likely were not includible pursuant to s. 6(1)(b), CRA stated: Generally speaking, a regular place of work is any place to or from which an employee regularly reports or performs the duties of the employee’s employment. … [Here] the place of work designated in the employment contract is not a regular place of work for the new employees. Consequently, travel between the residence of one of these employees and the employee’s place of work designated in the employment contract would be travel in the performance of the duties of the employee’s office or employment. … Consequently, should the Employer pay a reasonable allowance based on a kilometric rate for employees to use their private vehicle in the submitted situation, that allowance will come within the exception in subparagraph 6(1)(b)(vii.1). ...

In finding that the refund application should be denied, the Directorate stated: [W]here the specific conditions of subsection 227(6) have not been met, the implied exception rule … prevents relief from being available under the more general provision of subsection 220(2.1). Such relief would not be harmonious with … the intention of Parliament to limit Part XIII refund applications to two years after the end of the calendar year in which the amount was paid to the non-resident. … [T]here is no relief available to a taxpayer under the Canada-Barbados Tax Convention to override the two-year limitation period required by subsection 227(6). ...

The Directorate stated: [A]cceding to the taxpayer’s request to amend the return filed for the particular year would require the loss carryback to be eliminated and would have no impact on the tax payable for that year … [so that] no reassessment would be required. Accordingly … the Minister may, at any time, notify again the taxpayer that no tax is payable. However, although on “receiving a request to amend a return, the Minister is required to examine the amended return and issue a reasonable decision … [w]here it would not be appropriate for the Minister to accept the taxpayer’s request to amend the return, the Minister can deny the request.” ...

In summary, for the purpose of Article 5(3)(b) … the term “six months” generally means the aggregation of the number of days in six months … [being] 183 days …. ...

The Directorate responded: [The] “spousal plan” … definition does not refer to a transfer of an amount from an RPP to an RRSP. … [T]he Act does not require the trustee of an RPP to keep a record that an amount was transferred to the trustee from an RRSP that was a spousal plan. … In circumstances where taxpayers make transfers between RRSPs or RRIFs through an RPP in order to avoid the attribution rules in subsections 146(8.3) or 146.3(5.1), the Agency may consider applying the general anti-avoidance provision. ...

1 September 2015 Internal T.I. 2013-0507381I7- Transfer pricing adjustments and gross revenue-- summary under Subsection 247(2) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2) [s. 247(2) increases to gross revenues] CRA considered that an upward adjustment to a Canadian resident’s sales proceeds – but not a downward adjustment to its purchase price for goods – increased its gross revenue for provincial income allocation purposes. ...

1 September 2015 Internal T.I. 2013-0507381I7- Transfer pricing adjustments and gross revenue-- summary under Gross Revenue Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Gross Revenue sales (but not purchases) transfer pricing adjustments to gross revenue CRA considered that an upward adjustment under s. 247(2) to a Canadian resident’s sales proceeds – but not a downward adjustment to its purchase price for goods – increased its gross revenue for provincial income allocation purposes. ...

. … As a result, the TFSA trust would be considered to have borrowed money”. … However, where an overdraft is created in respect of fees charged to the TFSA but which remain unpaid… [this] would not constitute borrowing of money or other property for the purposes of paragraph 146.2(2)(f). … Turning to the cashless exercise of warrants, CRA stated: [T]he broker advanced the funds to the TFSA trust necessary to exercise the warrants in question. ...