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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. ...

(e) exclusion, stating that “the goods or equipment to be transported by the motor vehicle … must be distinct from the motor vehicle itself.” ...

This has the effect of applying the old rules on support, which means that Monsieur could deduct the amounts paid and Madame would be taxed on the amounts received under that judgment …. ...

In either case, the entire amount should be included in income on December 15, 1999, the date the advance was received … [per] paragraph 28(1)(a). ...

25 February 2002 External T.I. 2000-0046485 F- Majoration et Immobilisation-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) co-operative use of s. 88(1)(d) bump by targets and purchasers could entail acting in concert Planning to equalize assets of two target corporations (Aco and Bco) in connection with their sale to two purchasers (HoldcoA and HoldcoB)- which entailed a preliminary s. 85(1) rollover of equaling property by Aco and Bco, followed by the purchase of Aco by HoldcoA, and Aco’s s. 88(1) wind-up into HoldcoA to bump the preferred shares received on such s. 85(1) rollover, followed by a sale of the bumped shares by HoldcoA to HoldcoB – was considered to likely entail all the parties acting in concert so that they could not be considered to be dealing at arm’s length. ...

On the other hand, it could be subject to the general restriction described in section 67 …. ...

12 March 2002 Internal T.I. 2001-0094067 F- DEDOMMAGEMENT- TITRE DE PROPRIETE-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) damages received for separated spouse’s unlawful use of taxpayer’s property were tax-free receipts Monsieur received damages from his separated common-law spouse (Madame) to compensate him for her use of his ½ co-ownership interest in a property as if she were the full owner. ...

12 March 2002 Internal T.I. 2001-0094067 F- DEDOMMAGEMENT- TITRE DE PROPRIETE-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees legal fees incurred in ownership dispute were capital expenditures After his discovery that his separated common-law spouse (Madame) was selling a property in which he had a ½ co-ownership interest, Monsieurs obtained a judgment requiring recognition through a deed of his co-ownership interest and a second judgment requiring her to account for her management of the property in the interim, which resulted in Monsieur receiving a lump-sum damages payment. ...

In addition, the fact that the obligation is held for the short, medium or long term does not change the nature of the premium …. ...

. … Where a taxpayer holds a bond as a trader or dealer, we are of the view that any loss on the disposition of the bond that is attributable to the payment of a premium will be a loss on income account. ...