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However, turning to the Treaty, the Directorate stated: To the extent the Upfront Payment is subject to Part XIII tax under subparagraphs 212(1)(d)(i), 212(1)(d)(iv) or paragraph 212(1)(i), the Upfront Payment should be exempt from Canadian withholding tax under Article VII …. A substantially similar definition of the term “royalties” [to that in the Treaty] is found in Article 12 of the Model Convention …. ...

. … If the cost of the party is greater than $150 per person, the entire amount, including the additional costs, is a taxable benefit.” CRA then stated: [T]he "per person" cost of $150 for this position is based on the total number of people attending the party or social event. … [A] person who is invited to a party or a social event but who does not attend has not received or enjoyed a benefit. ...

The Directorate stated: Since the wording of subsection 105(1) refers simply to a "taxpayer", we are of the opinion that this provision may apply to a taxpayer who has received a benefit from a trust of which the taxpayer is neither a beneficiary nor a trustee, even if the taxpayer is not related, directly or indirectly, to a beneficiary or trustee of the trust …. Subsection 105(1) can therefore apply to Canco, notwithstanding Canco not being a beneficiary …. ...

From the perspective of the partner receiving such an allowance, it constitutes a distribution that reduces the adjusted cost base (ACB) of the partner's interest in the partnership pursuant to subparagraph 53(2)(c)(v) …. ... For the partner, this payment will be treated as a distribution and an adjustment to the ACB will be required pursuant to subparagraph 53(2)(c)(v) …. ...

. … [I]nterest paid to a partner … will generally receive the same tax treatment as management fees or bonuses. ...

. … This situation is similar to that considered ….in... Irving Oil …. ...

If the weekly allowance … was to compensate the employee for actual expenses for "board and lodging" at the special work site, we are of the view that the amounts would be considered reasonable …. ...

Consequently … subsection 146(12) would be applicable [here]. … While it may be appropriate for the issuer to use the services of an independent valuator to determine the FMV, this is not specifically required under the Act. ...

24 June 2004 Internal T.I. 2004-0065301I7 F- Frais médicaux- purificateur d'air-- summary under Paragraph 5700(c.1) Summary Under Tax Topics- Income Tax Regulations- Regulation 5700- Section 5700- Paragraph 5700(c.1) air exchanger can also serve as air purifier/ “severe” excludes seasonal allergies Regarding the eligibility of the cost including installation of an air exchanger that also functions as an air purifier and that operates only with a Hepa filter, CRA stated: [T]he fact that a piece of equipment has the dual function of being an air exchanger as well as an air purifier would not automatically exclude it from paragraph 5700(c.1) …. However, if an air exchanger and an air purifier are two separate devices that could be purchased separately … only the cost of the air purifier could be allowable Regarding the meaning of "severe chronic respiratory ailment," CRA noted the following statement on the Health Canada website: There is no universal definition for chronic respiratory diseases. ...

After finding that the storage tank did not fall within Class 8(c) as the Directorate did “not believe that the settling tank is a building and that it was acquired for the purpose of "manufacturing or processing" as … decantation is not a physical or chemical change produced by a technique of preparation or handling but rather a change resulting from a natural process,” the Directorate went on to find that it qualified under Class 6(e), stating: [T[he settling tank is a water storage tank …. ...