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. … Subject to certain exceptions under subsection 4(3) … subsection 4(2) … specifically denies the deduction of items in sections 60 to 64 … in determining income from a particular source. Consequently, a deduction allowed under paragraph 60(s) … is not tied to a particular source …. The amount determined under paragraph 3(c) … which forms variable F of the “non-capital loss” definition in subsection 111(8) … will never be negative, and therefore deductions described in Subdivision E of the Act cannot create or increase the amount of a non-capital loss. ...

7 October 2022 APFF Roundtable Q. 11, 2022-0942751C6 F- Changement de fin d'exercice et opposition-- summary under Subsection 165(3) Summary Under Tax Topics- Income Tax Act- Section 165- Subsection 165(3) CRA will not vacate an assessment that was not invalid or unfounded 2020-0874951I7 indicated that if a request for a retroactive change to a taxation year is made after the corporate tax returns are filed but before the first Notice of Assessment for that year is issued, it will generally be granted – but not if such request is made after such issuance. ... In rejecting this approach, CRA stated: For the purposes of subsection 165(3), an assessment may generally be vacated upon receipt of a Notice of Objection if a taxpayer submits additional facts or compelling arguments that were not before the Minister at the time the assessment was made and that demonstrate that the assessment is either invalid … or was unfounded …. [Here] … the mere fact that the corporation wishes to change the timing of its fiscal period end after tax has been assessed for the year corresponding to the fiscal period, even if it is the corporation's first fiscal period, does not, in and of itself, invalidate or render unfounded the [initial] assessment …. ...

8 October 2010 Roundtable, 2010-0373241C6 F- Acquisition of Control-- summary under Subsection 256(6.1) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(6.1) purpose is to take into account simultaneous control at the various levels In the course of a non-committal response as to whether there is an acquisition of control of a public company when its shareholders exchange most of their shares for shares of a Newco, CRA responded: [S.] 256(6.1) … is the legislative response to … Parthenon Investments …. ...

CRA responded: [S.] 256(6.1) … is the legislative response to … Parthenon Investments …. ...

CRA responded: In … IT-99R5 … the CRA confirms that legal costs incurred to enforce pre-existing rights to interim or permanent support amounts are deductible. ... As a result of … Gallien v. The Queen … 2000 DTC 2514 … legal costs incurred to obtain spousal support pursuant to the Divorce Act, or under provincial legislation in the case of a separation agreement, are also deductible. However, in the case of common-law spouses, the legal costs incurred to negotiate either a … cohabitation contract or a separation agreement are for the establishment and negotiation of an entitlement to support. ...

CRA responded: [F]or the 2016 and subsequent years,... taxpayers who have failed to report the disposition of their principal residence [are required to] amend their income tax return …. For the sale of a residence in 2016, Schedule 3 … must be completed, on which must be stated the year of disposition of the property, its proceeds of disposition as well as its description. … Form T2091 … (or Form T1255 …), is required for the designation if the property was not the taxpayer's principal residence for all the years in which the taxpayer was the owner. For dispositions in 2017 and subsequent years … taxpayers will also be required to complete Form T2091 (IND) (or Form T1255). ...

. … As indicated in paragraph 2.58 of … S1-F3-C2 … paragraph 45(1)(c) applies where the partial change in use of the property is substantial and of a more permanent nature. ...

The corporation no longer needs the policy on the executive’s retirement, and it transfers the policy to him for no consideration at a time when the particulars are: Death benefit $1,000,000 Cash surrender value $ 125,000 Adjusted cost basis $ 50,000 Fair market value $ 125,000 Without being queried on this issue, CRA stated: Although there are certain exceptions in the "advantage" definition, a benefit arising from the RCA holding a life insurance policy is not among them. ...

5 October 2018 APFF Roundtable Q. 9, 2018-0768801C6 F- Tax on Split-- summary under Subparagraph (a)(i) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares- Paragraph (a)- Subparagraph (a)(i) portfolio investment company might qualify as having a business 2018 STEP Roundtable Q.6 and Q.7 confirmed that the shares of a holding company (or of a company generating no business income) cannot qualify as excluded shares, whereas Examples 8 to 12 of CRA’s “ Guidance on the application of the split income rules for adults ” and the Department of Finance’s “ Technical Backgrounder on Measures to Address Income Sprinkling ” provide that such shares so qualify. ... CRA stated: The CRA's response to [Q.7] …was based on the assumption made in the statement of that question that the corporation had no business income. … …[In its Guidance] … to demonstrate that the various exclusions were applicable … to entities carrying on a business whose principal purpose is to derive income from property, including interest, dividends, rents and royalties, such as investment management corporations (in Examples 8 and 12), the CRA assumed that these corporations maintained a sufficient level of activity such that their income could be considered as derived from such a business. ... X, her shares are “excluded shares” if such $100,000 of income was “derived from the carrying on of a business the purpose of which is to earn interest income and dividends … notwithstanding the fact that the capital used in the acquisition by Holdco of the property used in carrying on its business was derived from dividends received from Opco.” ...

After indicating that the employer likely would not have a deemed permanent establishment in Ontario by virtue of this arrangement unless the employer was carrying on business in Ontario through the cottage, CRA went on to state: Even if the CRA were to conclude that … Mr. ... X's remuneration. … [T]he deeming rules in I.T.R. subsection 400(2) … do not … extend to I.T.R. sections 100 and 102, which are relevant to determining whether an employee reports for work at an establishment of the employee’s employer located in a particular province, as well as in determining the amounts to be deducted or withheld by the employer from the employee's remuneration. ...