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The Directorate stated: [T]he expression "an expense incurred... for the purpose of providing … for an eligible child of a taxpayer, child care services " is sufficiently flexible to include mandatory registration fees that allow an eligible child access to a daycare service. ...

9 August 2002 Internal T.I. 2002-0145817 F- TAUX DE DEDUCTION- PTPE- ANNEE 2000-- summary under Paragraph 38(c) Summary Under Tax Topics- Income Tax Act- Section 38- Paragraph 38(c) BIL realized under s. 50 at end of year (2000) so that ½ an ABIL An allowable business investment loss was recognized by an individual in an amount equal to ½ the business investment loss (BIL) realized by the individual in 2000 given that such loss arose from a deemed disposition pursuant to s. 50(1) which, therefore, was deemed to have occurred on December 31, 2000. ...

3 April 2019 Internal T.I. 2018-0787561I7- Partnership and the Meaning of "Related"-- summary under Paragraph 251.2(2)(a) Summary Under Tax Topics- Income Tax Act- Section 251.2- Subsection 251.2(2)- Paragraph 251.2(2)(a) partnership agreement illuminates which partners control a corporation held by the partnership In the course of a routine response, CRA noted its position that “when a partnership owns shares in a corporation … [t]he partnership agreement and the equity interest of the members must be examined to determine which member(s) of the partnership can exercise voting rights in respect of the shares of the corporation. In the case of a limited partnership … it is usually the general partner that can exercise these rights.” 2000-0038055 F and 2013-0484031E5 are similar. ...

The remuneration that the taxpayer received between Date 1 and Date 2 was, therefore, … employment income…. [T]he amount paid as compensation for cessation of employment on the day following Date 2…[and] the amounts calculated on the basis of the net salary paid between Date 2 and Date 3, and the final lump sum, if any, … were intended to compensate the taxpayer for the loss of employment and would not have received had it not been for the loss of employment. ... Furthermore, in spite of the fact that contributions of the taxpayer to the pension plans continued to accumulate for the period from Date 4 to Date 5, … the taxpayer and the employer did not have an employment relationship during that period…since [citing Schwartz] she was not required to provide services. … Thus, since… there was no beginning of employment on Date 4… the amounts paid between Date 4 and Date 5 constituted the continued payment of a retiring allowance. ...

. … [The subsequent year’s payment] is paid to the right-holder in lieu of a superannuation or pension benefit to which the right-holder would otherwise have been entitled, had it not been for the application of the UPA … [and] is to be included in the computation of the right-holder’s income for the year in which the DPBNR pays it to the right-holder. Where the right-holder is an estate, it should include the survivor benefit under s. 56(1)(a)(i) in computing its income for the year of receipt – but with a deduction to it and an inclusion to its beneficiaries being applicable where those amounts are distributed in accordance with the usual ss. 104(6), (13) and (24) rules. The Directorate went on to state, respecting where the administration of the estate has been completed prior to the DPBNR being in a position to pay the amount: [T]he CRA will not object to the beneficiaries of the estate who are entitled … to all or part of the survivor benefit amounts being considered to have received those amounts directly from the DPBNR. ...

Before [any] corresponding adjustment is made … the conditions of paragraph IV(6) should still be met since Parentco is considered to have derived an amount (that is not disregarded) through US Sisterco LLC. More specifically … from a US tax perspective, Parentco, will have a reduced cost of inventory that is derived through the purchases of Sisterco LLC from Canco. ... Either way … that amount [is not] “disregarded” for US tax purposes …. ...

The Directorate stated: Generally, corporations in Canada have the following characteristics, among others: Legal personality … Limited liability of shareholders and a corporation can incur losses for which the members are not liable; Issuance of share capital to shareholders; Distributions: shareholders of a company are entitled to the division and distribution of profits after they are declared by the corporation; Centralization of management; Free transferability of interests; Incorporation by statute or by the registration of memorandum of association. ... Before finding that the SCSs were partnerships for ITA purposes, the Directorate stated: Given that Côte d’Ivoire and Gabon are civil law systems and that Quebec is the only province that has a civil law system in Canada, it is appropriate to primarily compare the SCS to partnerships formed under the Civil Code of Quebec. … Under Article 2219 of the Civil Code of Quebec (“CCQ”) … a partnership can conclude contracts in its own name. Article 2225 … provides that a partnership may sue and be sued under the name it declares. ...

The Directorate responded: [I]t is imperative to validate that the amount was paid or reimbursed under a services contract …. ... [A]ssuming that a contractual relationship exists between the consultants and the federal agency payer … reimbursements for travel expenses should be disclosed on the T1204 form. ...

. … Generally, the CRA considers that a presence on a weekly basis at the establishment of the employer, for a duration of the equivalent of a typical day’s work of the employee in fulfilling the employee’s normal workload, is sufficient to lead to a conclusion that the employee reports to work there. … [A]n employee who is not considered as reporting to a given establishment of the employer will be deemed to report for work at the establishment of the employer from which the remuneration is paid by virtue of subsection 100(4)…. ...

. … Subsection 108(5)… provides that amounts included in the Taxpayer’s income under subsection 104(13)… shall be deemed to be income from property that is an interest in the trust and not from any other source. … [T]he income that the Taxpayer has received is deemed to be income from an interest in a trust; it does not retain its character as dividend income. ...