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. … However, should the CRA accept the contention that a postdoctoral fellow receives a scholarship and can claim the education tax credit, it would still be of the view that the postdoctoral fellow could not claim the scholarship exemption unless the amount so received was sufficiently related to the qualifying educational program for which the education tax credit is claimed. ...

. … [Here] the contribution was not made within the first 60 days of the calendar year. ...

. … Krauss... supports that position. …[Y]our example is similar to the situation in Krauss and that subsection 103(1.1) could apply in your example. ...

26 July 2010 External T.I. 2010-0364721E5 F- Revenus de bien et d'entreprise-- summary under Subsection 1100(14) Summary Under Tax Topics- Income Tax Regulations- Regulation 1100- Subsection 1100(14) rental property restriction rule applies to business properties as well/"principally" references over 50% of the time After concluding that “the operator of a bed and breakfast, who has a personal residence in which bed and breakfast rooms are rented out on a short-term basis, is generally considered to be carrying on a business” rather than having a source of property income, CRA stated: Whether or not the rental of a building by an individual is a business, the property may be considered a "rental property" for purposes of the CCA restrictions under subsection 1100(11) …. ...

. … [T]hat provision does not have the effect of allowing the annuitant of a RRIF to share with the annuitant’s deceased spouse or common-law partner the tax burden applicable to the annuitant because of the RRIF. ...

. … Depending on the circumstances, the application of the presumptions in subsection 7(1.3) could result in the requirement of paragraph 110(1)(d.01) in respect of the acquisition of securities in the year of disposition not being satisfied. ...

After noting that “the will must require the executor … to distribute the bequeathed property to the designated legatee,” CRA stated: [A] gift the amount of which is left to the discretion of the executor or the deceased's legal representative is not a gift made by will. ...

In this case, since there is no exception in subsection 67.1(2) that would allow the Taxpayer to avoid the application of subsection 67.1(1) … expenses incurred by the Taxpayer for food and beverages paid for during restaurant visits should be subject to the restriction in subsection 67.1(1). ...

. … [I]t is the selling party, Corporation A, that paid non-business-income tax to the government of a country other than Canada for the purposes of paragraph 126(1)(a), which can, therefore, compute a foreign tax credit under subsection 126(1). ...

12 January 2011 Internal T.I. 2010-0375801I7 F- Bien agricole admissible détenu avant 1987-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property property status of Quebec lands divided into cadastral lots was analyzed on a lot-by-lot basis Before finding that Quebec lands that had been devised to a widow by her farmer husband, who used only part of the lands in his farming business, should be analyzed on a cadastral lot-by-lot basis, respecting meeting the tests in s. 110.6(1.3)(c)(ii), so that only those lots that had been used by deceased husband in farming so qualified, the Directorate stated: [C]adastral lots are considered, for the purposes of the Act, to be separate real property …. ...