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In 2017-0735771I7, Headquarters considered that such loss was suspended on the basis that, for purposes of s. 40(3.5)(c)(i), Bco was a corporation “formed” on the “merger” of CCo with BCo – with the result that BCo was deemed to continue to own the shares of CCo with which it was affiliated, notwithstanding that CCo had, in fact, ceased to exist. ... Headquarters, in this Interpretation, clarified that such winding-up of BCo could be a “designated liquidation and dissolution” described in s. 95(2)(e) – in which event, s. 95(2)(e)(v)(A)(III) would deem DCo to be a continuation of BCo for s. 40(3.5)(c) purposes respecting shares that were deemed under that paragraph to be owned by BCo before the DLAD (i.e., respecting its deemed continued ownership of the CCo shares) – so that the loss on the CCo shares continued to be suspended. ...

. … Whether a particular debt obligation, such as a line of credit, a demand loan or a forgivable loan, is secured by a mortgage or hypothec on the qualifying property is a question of fact and law …. [A]lthough interest paid on a debt obligation (such as a line of credit, a demand loan or a forgivable loan) secured by a mortgage or hypothec on a qualifying property may be considered qualifying rent expense, if it has no amortization period, the principal amount of the debt obligation would not be included in the LTPA Limit described in clause (b)(i)(A) …. ...

.) – 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 reimbursements were not includible pursuant to s. 6(1)(a), CRA stated: [T]ravel between an employee's residence and a place of work other than a regular place of work is generally considered to be in the performance of the duties of the office or employment. … 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. ...

Rye / Klein line of cases): It is well established at common law that a man cannot contract with himself and that a partner cannot contract with a partnership of which he is a member. ... Act: “A limited partner may loan money to and transact other business with the limited partnership … ” (i.e., s. 12 does not specifically refer to limited partner borrowings). ...

The Directorate indicated that such a request could be granted since it would have no impact on the tax payable for the particular year, but “emphasize[d] … that there is nothing in the Act that compels the Minister to automatically accept such requests.” However, the Directorate noted that if the amendment request was accepted, the accrued interest would be eliminated, stating: Pursuant to subsection 161(1), interest is computed when there is an excess of tax payable over the tax paid on account of tax payable by a taxpayer. … [Here] the acceptance of the taxpayer’s request to recharacterize part of the income it previously reported in its tax return would result in the Minister acknowledging that the income was of capital nature from the moment it was earned rather than business income. … [H]ad the taxpayer filed its initial tax return on that basis, the tax payable would be nil and a notification of no tax payable would be issued. ...

Regarding the first assumption, CRA stated: [T]he better position is that [s. 163(1)] does not apply where a taxpayer files T1 income tax returns simultaneously for a number of consecutive taxation years and the taxpayer's income tax returns for the earlier taxation years were filed in accordance with the provisions of the Act …. … [T]he CRA should not apply subsection 163(1) respecting Mr. Y's unreported income under the first scenario …. Regarding the second assumption, CRA stated: [I]f the failure to report an amount to be included in Mr. ...

. … [T]o conclude that the portion of the salary paid to a chef hired by a corporation to prepare meals for the staff during the stages from the final script stage to the end of the post-production stage would be to ignore the adverb "directly" used by the legislator in paragraphs (a) and (b) of the definition of LE. … Similarly … the accounting fees that a corporation must incur to meet CFVP requirements and the legal fees that a corporation must pay to an actor's agent to negotiate the actor's contract are certainly expenses that are necessary and parallel to the production of a CFVP, but we doubt that those expenses are directly attributable (i.e., in immediate relation) to the production of a CFVP and relate to the final script stage to the end of the post-production stage. ...

The Directorate responded: Since the lump sum in this case was not paid in lieu of amounts payable periodically as described in paragraph 22 of … IT-530R … that amount is not a support amount within the meaning of subsection 56.1(4). ...

12 October 2010 Internal T.I. 2010-0355761I7 F- PCMC- Dépense courante ou en capital-- summary under Subparagraph (b)(i) Summary Under Tax Topics- Income Tax Regulations- Regulation 1106- Subsection 1106(1)- Excluded Production- Paragraph (b)- Subparagraph (b)(i) dealing with a currents topic does not render a program a news program Regarding the meaning of "news programming," CRA stated: [A] production dealing with a current events topic is not necessarily a news program and … a production dealing with a current events topic could, in certain circumstances, qualify for the CFVP tax credit …. ...

8 January 2008 Internal T.I. 2007-0254881I7 F- Amortissement d'une aire de camping-- summary under Class 6 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 6 swimming pool is a water storage tank Regarding the classification of a swimming pools in a campground, the Directorate stated: As for swimming pools that may be found at campgrounds, we are of the view that they are depreciable property included in Class 6(e) …. ... M.N.R. 56 DTC 537 (I.T.B.A.)- … conclude[d] that a swimming pool in a hotel complex was a water storage tank for the purposes of Class 6(e). ...