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After citing Transalta for the proposition that “a discretionary arrangement that does not give employees the right to require that equity-based compensation be paid in the form of shares rather than cash is not an agreement to sell or issue shares for purposes of section 7,” it stated: … USCo can unilaterally decide to settle RSUs payable to CanCo employees in the form of cash rather than issuing Shares. ...

(a)(ii) of the ERDTOH definition – whereas para. (b) of the NERDTOH definition includes all other Part IV taxes payable by the corporation on dividends from a connected corporation, the Directorate stated: A corporation will not have transitioned to the ERDTOH and NERDTOH regime in its taxation year that begins before 2019 and cannot receive a refund from its ERDTOH account with respect to dividends paid in that taxation year. ...

[G]iven that the office space was unoccupied since the eligible entity moved to a new office … the old office space would likely not be considered to be used in the ordinary activities of the eligible entity. ...

It was “Rulings’ view that allowing subsection 220(2.1) to waive a taxpayer’s requirement to file an election not listed in Regulation 600 would negate the specific intention of Parliament in limiting late elections to only those that are prescribed in [Reg.] 600” – and, in any event, the CIF provision was not a provision of the Act itself, as required by s. 220(2.1). ...

It was “Rulings’ view that allowing subsection 220(2.1) to waive a taxpayer’s requirement to file an election not listed in Regulation 600 would negate the specific intention of Parliament in limiting late elections to only those that are prescribed in [Reg.] 600” – and, in any event, the CIF provision was not a provision of the Act itself, as required by s. 220(2.1). ...

. … Given the fact that a non-resident that receives a letter containing proposed assessed amounts would almost certainly make a valid paragraph 94(3)(f) election before an audit assessment is actually issued, it appears unlikely that such a non-resident would ever be prevented from making a valid election. ...

Before concluding that (by virtue of the exception in s. 67.1(2)(c) s. 67.1(1) did not limit the deduction to the taxpayer for its incurring of the meal allowances and that such limitation instead applied to the purchasers respecting the cumulative amount of the meal allowances referred to in the interim invoice note, CRA indicated: The expression “amount … compensated” in s. 67.1(2)(c) was used in the sense of “paid or reimbursed”. ...

In finding that the correction of the terms of the partition through the partial mortgage assumption by A did not produce proceeds of disposition to B (and before finding that the compensation to B for the excess interest payments he had made on such assumed mortgage amount produced a s. 12(1)(x)(iv) inclusion to him), the Agency stated: [W]ithin the framework of the out-of-court settlement agreement, Brother A and Brother B genuinely intended to correct the error that occurred during the partition … [and] they did not intend to pay compensation (a cash payment) to offset the inequality in the partition. ...

. … [I]n... Kaiser... 91 DTC 1057...the taxpayer tried [unsuccessfully] to convince the Tax Court that foreign taxes paid on employment income were deductible under subsection 20(12).... ...

. … Justice L'Heureux-Dubé seemed to suggest that Mara Properties stands for the proposition that subsection 88(1) deems the parent to have received property of the same character from its subsidiary upon the subsidiary's wind-up. ...