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Profit- Short Sales "... We would consider a short sale entered into in order to hedge a taxpayer's position with respect to identical shares held on capital account to be a short sale that is on capital account. ...

In rejecting the retroactive application of this provision, the Directorate stated: Although an order dated after April 1997 may deem or stipulate that child support amounts payable or receivable after that date will be subject to the pre-May 1997 support rules … we are of the view that such tax consequences do not arise because an order has so stipulated. ...

Regarding the resulting disposition of the spousal beneficiary’s income interest, it indicated that there would be no amount to include in the beneficiary’s income pursuant to s. 106(2) as s. 106(3) would apply – but s. 106(3) would have no adverse consequences assuming that the property distributed was cash. ...

16 August 2001 Internal T.I. 2001-0079317 F- RESIDENCE PRINCIPALE DEMI-HECTARE-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence- Paragraph (e) exemption could be claimed only for one lot/ CCRA does not normally challenge contribution to enjoyment of residence of under ½ hectare if no commercial use The taxpayer acquired a lot on which he constructed a residence and also used in part for business purposes and also acquired an adjoining lot on which he erected buildings used for business purposes. ...

In addition … an amount declared by a cooperative to be a patronage dividend to a member, computed on the basis of the volume of work performed directly or indirectly by that member for the cooperative, would be a deductible amount pursuant to subsection 135(1) since it would meet the definition of "allocation in proportion to patronage". ...

CCRA responded: [A] designation filed by a corporation pursuant to paragraph 88(1)(d) in its return of income under Part I of the Act for its taxation year in which its subsidiary was wound-up, in a situation similar to the one … described, could not be considered invalid solely because the amount designated by the parent corporation was overstated. ...

Furthermore … the damages do not represent employment income. The amounts received for material and moral damages would therefore not be taxable. ...

Furthermore, “suretyship is generally distinguished from insurance on the basis that the latter compensates for a loss that may arise from a future and uncertain event, whereas suretyship generally covers an existing obligation to a creditor” – so that the partnership was not providing insurance. ...

. … [I]f a trust governed by an RRSP or a RRIF continues to hold property after December 31, 2001 to which paragraph 4900(1)(s) of the Regulations applied, the tax that the trust will have to pay under Part XI.1 of the Act will be computed at 1% of the fair market value of the property at the time it acquired it. ...

CCRA indicated that the standby benefit would be computed based on the corporation’s cost of $22,500 and the number of 30-day periods during which the automobile is available to the employee – unless the kilometres driven personally was fewer than 1,000 kilometres per month and all or substantially all (i.e., 90%) of the distance travelled by the automobile during the total number of days in the year it was made available to the employee was in the performance of the duties of his employment. ...