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8 November 2006 External T.I. 2006-0176171E5 F- Revente d'un bien amortissable- alinéa 13(7)e)-- summary under Subparagraph 39(1)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(b)- Subparagraph 39(1)(b)(i) capital loss denied on sale of building – proceeds reflected in UCC reduction Corporation A sold a building with a cost of $3,800,000 to an associated corporation (Corporation B) for its FMV of $4,200,000, so that s. 13(7)(e) reduced its cost to Corporation B to $4,000,000. ...

Under element A of the formula in the CEC definition of CEC, the balance in Newco's CEC account as at December 31, 2003 was $500,000, reflecting a reduction for ½ of such s. 14(1)(b) inclusion. ...

Consequently, subsection 70(9.2) would not apply … Words and Phrases consequence of the death ...

As a result, any gain accrued on the entire property would have been recognized at that time – but such gain would have been offset by the principal residence exemption. ...

Similarly, hairdressing expenses incurred by the taxpayer are not deductible since the taxpayer incurs them in order to report for work …. ...

. … The CRA is of the view that an obligation such as the one described in the above example is not an obligation described in paragraph 7000(1)(b) and therefore the provisions of subsection 12(9.1) do not apply. ...

14 September 2017 Roundtable, 2017-0703871C6- CPA Alberta 2017 Q9: PHSP for owner-managers-- summary under Subparagraph 6(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) sole employee-shareholder unlikely to qualify for PHSP CRA considers that: In a situation where a corporation provides a self-insured HCSA for its only employee who is also its sole shareholder …, it is likely that the sole employee-shareholder would be reimbursed for the full amount allocated to him or her annually. ...

21 March 2005 Internal T.I. 2005-0119961I7 F- CCPC STATUS-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date effective date of transfer of shares (entailing acquisition of control) cannot precede determination of essential contract elements USco disposed of 50% of the shares of Canco to another corporation ("Holdco" – that was a Canadian-owned Canadian corporation), "retroactive" to a particular date. ...

CRA noted that the daughter would receive the net rental income as the income beneficiary of a deemed trust under s. 248(3) (so that such income was deemed to be income from property under s. 108(5)(a)) – except that when the usufruct was extinguished, there would be a dissolution of the deemed trust to which s. 107(2) would apply, so that thereafter the bare owner would become subject to tax on the rental income. ...

CRA stated: [T]he revenues that Opco would earn in a particular year from the Second Crushing activity could be included in computing its GRP for that year under clause 1204(1)(b)(iii)(A) … since they could constitute revenues for the year from the processing in Canada of ore derived from mineral resources in Canada that would not be mined by Opco to any stage that is not beyond the prime metal stage or its equivalent. ...