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CRA responded: The arrangement … appears to be one of bartering whereby the PSB provides services to its client in exchange for the use of an automobile and possibly other consideration paid by the client. ... In arm’s length transactions, where an amount must be brought into income, that amount is the price which the PSB would normally have charged a stranger for its services. … If the individual shareholder of the PSB is using the automobile for his/her own personal-use, a benefit under one of subsection 6(1), 15(1), 56(2) or 246(1) of the Act may need to be included in the individual shareholder’s income. ...

In finding that this was insufficient to give rise to a capital dividend “received,” so that there had been no addition to the capital dividend account of Parentco, the Directorate stated: [T]he mere making of the accounting entries … does not in itself constitute the payment of a dividend … by either Subco or Parentco. ...

As noted above, the mere making of the accounting entries … does not in itself constitute the payment by Parentco and receipt by Mr. A of a dividend …. ...

. … Paragraph 18(1)(h) does not impose any minimum distance or duration requirements regarding the deductibility of a meal. … [M]eal expenses incurred by a self-employed person in respect of meals consumed alone at lunchtime are generally not expenses incurred by the self-employed person in the course of carrying on the person’s business and for the purpose of earning income from the business. ...

… In the absence of further information demonstrating that the amount paid by the employer was intended to compensate the taxpayer for items such as wages that should have been paid to the taxpayer during his period of employment and/or damages relating to the harassment complaint made during the period prior to his loss of employment, we are of the view that the definition of retiring allowance in subsection 248(1) is intended to refer to the $XXXXXXXXXX received by the taxpayer …. ...

2 October 2006 Internal T.I. 2006-0168081I7 F- Actions d'une société en faillite-- summary under Subparagraph 50(1)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 50- Subsection 50(1)- Paragraph 50(1)(b)- Subparagraph 50(1)(b)(i) s. 50(1)(b)(i) satisfied if notice of intention under BIA does not lead to timely filing of proposal – but election must be filed for that rather than subsequent year After the appointment of a trustee, two subsidiary corporations of the taxpayer corporation filed notices of intention under s. 50.4 of the Bankruptcy and Insolvency Act ("BIA") to make a proposal, and renewed the notices. ... Furthermore: Given that the legal status of a taxpayer differs depending on whether it is bankrupt or merely insolvent … the provisions of subparagraph 50(1)(b)(iii) are not intended to cover the situation of a taxpayer who has become bankrupt. ...

After noting that the loan was assistance for the purposes of s. 12(1)(x) and the definition thereof in s. 125.4(1), and reduced Prod Co's "labour expenditure" s. 125.4(3), the Directorate considered whether there would be such assistance if M Co instead invested the sum in shares of Prod Co, and stated: [I]f, in order to partially finance a production, Prod Co issues shares of a class of its capital stock to its parent company M Co, the latter acquires … rights in Prod Co through the shares issued to it for the purposes of subparagraph 12(1)(x)(viii) … [and] the acquisition of those shares does not constitute an amount of assistance to Prod Co for the purposes of section 125.4. ...

We consider those benefits to be "social assistance benefits" …. … The benefits are not solely for the benefit of an Indian resident on a reserve and are therefore not personal property of an Indian resident on a reserve and are therefore not exempt from taxation under [the Indian Act]. ...

22 August 2017 Internal T.I. 2017-0688301I7- Restrictive Covenant-- summary under Paragraph 56.4(3)(c) Summary Under Tax Topics- Income Tax Act- Section 56.4- Subsection 56.4(3)- Paragraph 56.4(3)(c) agreement not to solicit employees not assimilated When presented with an agreement for the sale of the shares of a private company under which various shareholders were required to agree to a non-competition covenant (“NCC”) and a non-solicitation covenant (“NSC”), the Directorate found that “essentially, the terms of the NCC and NSC … reflect the conditions that one might normally expect to see in a typical non-competition agreement,” so that they “could be treated as a single RC [restrictive covenant] that is in respect of a non-compete covenant.” ... Before so concluding, the Directorate noted that, in dealing with the similar language in s. 56.4(3)(c)(ii), it had considered that s. 56.4(3)(c)(ii) … would allow an election with respect to the undertaking not to solicit the clients of the corporation that is sold, but it would not allow such an election with respect to the value of an undertaking not to solicit the employees to change employment... and that the fact that a non-competition agreement may include both a non-competition and a confidentiality clause would not in and of itself disqualify the entire non-competition agreement for the purposes of the exceptions in subsection 56.4(3) or 56.4(7). ...

The Directorate went on to state: The surplus of CFA could conceivably be adjusted where CFA’s “earnings” are computed pursuant to subparagraph (a)(i) or (a)(ii) of the definition of “earnings” under [Reg.] 5907(1) … and the relevant foreign tax law makes its own transfer pricing adjustment, whether by way of a corresponding adjustment or otherwise. …[C]onsideration would have to be given to whether subsection 5907(2) … could reverse that foreign tax law adjustment and to the possible impact of any accompanying transfer of assets to effect a so-called “repatriation” payment. ...