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. … [A]lthough the Policy is property acquired for the purpose of earning income from property … these premiums are not deductible in computing the taxpayer's income because of the special rules applicable to life insurance policies. ...

It then stated: Consequently, the replacement property (passenger vehicle) will have to be placed in a separate class 10.1 under [Reg.] 1101(af) … and the reduction calculated under paragraph 13(4)(d) will be made to that class. No change of class may be made given the wording of [Reg.] 1103(2d) …. ...

16 November 2001 Internal T.I. 2001-0095617 F- ACCORD ECRIT RETROACTIF GARDE D'ENFANTS-- summary under Support Amount Summary Under Tax Topics- Income Tax Act- Section 56.1- Subsection 56.1(4)- Support Amount “agreement” must correspond “to the reality of a situation of shared financial and parental responsibilities and … [be] a valid contract … creating mutual obligations” After finding that a letter signed by the two separated spouses did not constitute an “agreement” for purposes of the “support amount” and “commencement day” definitions, the Directorate went on to state: A written agreement subsequent to an order could, in certain circumstances, be valid for the purposes of applying the terms "commencement day", "support amount" and "child support amount" if such an agreement corresponded to the reality of a situation of shared financial and parental responsibilities and if the agreement was a valid contract between two parties having the effect of creating mutual obligations. ...

In finding that this does not signify that he has realized a $25,000 gain on the land, and a $10,000 loss on the building which is denied by s. 40(2)(g)(iii), the Directorate stated: Where a building constitutes depreciable property … [Reg. 1102(2)] has the effect of splitting the property into two for the purposes of the Act, namely the land and the building. In the case of a cottage that is a PUP, we are of the view that the land and the building will remain one and the same property for tax purposes if they constitute one and the same property for legal purposes. … [Here] the taxpayer will realize a capital gain of $15,000 on the disposition of his property. ...

For the purposes of subsection 129(3) … the "dividend refund" means the amount equal to the lesser of the amounts set out in subparagraphs 129(1)(a)(i) and (ii). Consequently … the amount of Portfolioco's RDTOH account for its 1998 taxation year would be reduced by the $100,000 dividend refund that would have been made by the CCRA had Portfolioco filed its return of income in accordance with paragraph 150(1)(a). ...

In the case of an agent … the fees paid by the professional should be reasonable and correspond to the fair market value of the services rendered by the agent. Furthermore, if it were a genuine management company and not an agent of the professional, the CCRA would question the deductibility of the … fee if the management company had no employees to perform the functions for which the professional was billed. ...

. … [T]he reassessments would be attributable to FAPI arising directly from the contribution by the Taxpayer of the Marketable Securities to ForeignCo which … would be a "transaction" between Holdco and ForeignCo referred to in subparagraph 152(4)(b)(iii) that it would be reasonable to consider as relating to the reassessments for purposes of subparagraph 152(4.01)(b)(iii). ...

After referencing the requirement in s. 147.2(2)(a)(vi), which “ensures that any unfunded liability associated with a participating employer, and thus the employer’s contributions in respect of that liability, are not excessive,” and the s. 147.2(2)(d) requirement that “there is a reasonable determination of each participating employer’s actuarial surplus,” CRA stated that in such situation: [T]he particular employer would nonetheless continue to be considered a participating employer …. ... This helps avoid problems that could arise from experience gains or losses. … This position applies regardless of whether the particular employer ceases to exist, except where specific rules provide otherwise. ...

In 2017-0735771I7, Headquarters rejected this position 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 concluded that this resulted in the loss being de-suspended, stating: Upon the completion of the liquidation of BCo, it would no longer be affiliated with ACo. … Pursuant to subparagraph 40(3.4)(b)(i), the Suspended Loss will be deemed to be a capital loss of ACo immediately after the completion of the liquidation of BCo. ...

. … If the[re] is considered to be one failure, the taxpayer would only be liable to a maximum penalty of $100 under subsection 162(5) for failing to provide information. ... In our view, such an approach would “discourage taxpayers from being diligent and taking reasonable care in the preparation of their returns.” … [W]e suggest that care be taken to ensure that assessing penalties under subsections 162(5) and (7) is both appropriate based on the relevant facts of a situation and equitable to the tax community as a whole. ...