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. … [S]ubsection 104(24) provides a rule of application that alters the ordinary result…only if…an amount has first been determined to have become payable to a beneficiary. As no amount has become payable to a beneficiary pursuant to subsection 104(6), subsection 104(24) has no application. … By analogous rationale, in our view no amount may be included in computing the income for the year of a minor beneficiary under the trust pursuant to subsection 104(13) in this case. ...

. … Thus, to the extent that the annuitant acquired units of the Co-op from the trust governing his RRSP that have a nil FMV, the cost of the units to the annuitant would be deemed to be nil by virtue paragraph 69(1)(a). The excess amount paid by the annuitant to the trust governing the annuitant's RRSP would be treated as a premium, and could result in an over-contribution …. ...

After quoting from Quebec commentary that “[a]s a general rule, the mere delivery of a promissory note does not entail novation of the pre-existing obligation” and the “promissory bill is then considered as a simple means of acknowledging the debt,” CRA stated: [T]he issuance of the note … did not constitute a payment and that there was no novation of the original debt by reason of the issuance of this second note.” After quoting from Québec Cartier, CRA concluded that “the Taxpayer did not pay the increased and annually capitalized interest and did not credit the Vendor with such interest when the [new] note … was issued.” ...

In indicating that there generally was an increase to the ACB of their shares, the Directorate stated: [A] transaction that otherwise increases the capital of a corporation without any consideration being given by the corporation in respect of that increase may result in a contribution of capital …. ... However, paragraph 53(1)(c) will apply only where a contribution of capital to a corporation by a taxpayer holding shares of the capital stock of the corporation results in an increase in the fair market value of the shares of the capital stock held by the taxpayer. … [Here] the capital expenditures incurred by the Shareholders with respect to the Building constitute a contribution of capital to the Corporation. ...

X had not declared an amount in his 2004 return (the "first criterion at issue "). ... X would be subject to a penalty pursuant to subsection 163(1) for his 2004 taxation year …. ...

In this case … the applicable provision- permitting the deduction of amounts repaid in respect of employment insurance benefits- is paragraph 60(n)(iv). Since the taxpayer did not have any amounts to include in the taxpayer’s net income … the taxpayer cannot claim that deduction. ...

The Directorate stated: In general … there is no taxable benefit [where]: the value of the meal or meal allowance is reasonable: in general, an amount up to $17 is considered reasonable; The employee works two or more hours of overtime right before or right after their scheduled hours of work. ... In addition, this condition may be satisfied where a meal or allowance is provided at least three times a week on an occasional basis to meet ad hoc workload requirements such as major repairs or periodic financial reporting. … [A]n allowance that is higher [than $17] may still be reasonable if the cost of meals in a particular location is higher or if there are certain circumstances that justify a higher amount. ...

Thus … for purposes of computing the security required under subsection 220(4.5), an individual would generally be entitled to benefit from the Deemed Security even if his or her capital gain exceeds $100,000 …. ...

VII, s. 2) via the internet – but with the taxpayer required to attend the university in person three times a year for a period of one week at a time, so that travel and living expenses are incurred. In finding that the taxpayer could claim the tuition tax credit (“TCC”) respecting the tuition fees paid for the 2007 taxation year, the Directorate stated: [S]ince May 3, 2007, the CRA has considered that a student may claim the TTC in respect of courses taken via the Internet to the extent that the student can demonstrate that this is equivalent to attending university on a full-time basis and to the extent that the other conditions applicable to the TTC are satisfied. … Regarding travel and living expenses, those expenses are not considered eligible tuition fees. ...

CRA stated: Each of the Individuals carries on the day-to-day management of the Operator as would an officer or employee … [and] the Individuals are all specified shareholders of their management corporation …. ...