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Thus, the "Payroll Taxes" and "Social Security Taxes" in this situation must be considered "non-business income taxes" …. ...

23 September 2003 External T.I. 2002-0172175 F- Arrangements Funérailles- Provision 20(1)m)-- summary under Paragraph 12(1)(a) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(a) prepaid funeral amounts which a funeral home was not required to hold in trust were s. 9, not s. 12(1)(a), income Regarding the 10% portion of prepaid funeral amounts which a Quebec funeral home is permitted to use in its operations rather than being required to hold in trust, CCRA stated: The 10% amount is to be included in the income of the funeral arrangement vendor pursuant to section 9, rather than pursuant to paragraph 12(1)(a), and the reserve pursuant to paragraph 20(1)(m) cannot be claimed in respect of an amount included pursuant to section 9, since it has the nature and character of income …. ...

In addition, as noted in Shell Canada … "Where an interest rate is established in a market of lenders and borrowers acting at arms' length from each other, it is generally a reasonable rate.” ...

CCRA responded: Even if the withdrawal is not referred to as a "policy loan" under the terms and conditions of the policy, this does not mean that the withdrawal is not a "policy loan" …. ...

As stated in Shell, "[w]here an interest rate is established in a market of lenders and borrowers acting at arm’s length from each other, it is generally a reasonable rate… ". ...

The Directorate stated: [U]nder the terms of subsection 231.5(1) … where, pursuant to sections 231.1 and 231.2, electronic records (such electronic records being "records" within the meaning of the definition of "record" in section 231 and the definition of "record" in subsection 248(1)) are being audited or reviewed or produced, the person who is doing the auditing or reviewing, or to whom the production is made, or any CCRA official, may make or cause to be made electronic copies of them. ...

Where the buying power of money increases, the debtor must treat the reduction in the amount due under an indexed debt instrument as interest that the debtor received or was entitled to receive in the year – and the holder of the bond will be able to deduct the amount paid to the debtor. ...

. … [A]n issuer may not agree to transfer property to a RRIF trust where the property will not provide the necessary liquidity to make the minimum payments. ...

14 January 2004 External T.I. 2003-0026011E5 F- Contrat à terme sur indice boursier-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base unrealized gains or losses on stock index futures contracts not included in the ACB of such property Regarding whether unrealized gains or losses on stock index futures contracts should be taken into account in determining the "cost amount" of a property for purposes of former Part XI, CCRA stated: The Act … states that the cost amount of a property that is capital property is the adjusted cost base of the property, which generally reflects the costs or expenses incurred to acquire the property. ...

. … [W]hen computing the capital gain resulting from such a disposition, the costs incurred to receive such proceeds of disposition (such as legal fees and appraisal fees that have not been reimbursed) would be expenses incurred for the purpose of making the disposition and would be deductible when computing such gain. ...