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In such a situation, where the corporation is a private corporation … there is a presumption that the shareholders will act together to control the corporation. ...

CRA noted that if the trust elects in its T3 return for its first taxation year, then it will no longer fall within the scope of s. 104(4)(a) – and because it did not apply, CRA would consider that the settlor’s death would not be relevant for the purposes of the preamble to s. 104(13.4). ...

Suppose that a lump sum from the pension plan of the deceased is not received by the estate until beyond this 36-month period – and the executor is unable to distribute the income to the sole beneficiary before the end of the year of receipt. ...

Accordingly it cannot be said that banker's acceptance are obligations which are similar to bonds, debentures and notes …. ...

26 October 2021 External T.I. 2019-0800111E5 F- Psychothérapeutes du Québec, professionnels de la-- summary under Subsection 118.4(2) Summary Under Tax Topics- Income Tax Act- Section 118.4- Subsection 118.4(2) Quebec psychotherapists added to list of authorized medical practitioners CRA indicated that it “will shortly be adding” the words “psychotherapist legally authorized" to its list of Authorized medical practitioners for the purposes of the medical expense tax credit, so that “expenses incurred for psychotherapy services rendered by psychotherapists who hold a psychotherapy permit issued by the Ordre des psychologues du Québec will now be considered medical expenses … for purposes of the medical expense tax credit.” ...

Therefore, the 87(1)(a) condition would be met – all property of the predecessor corporation becomes property of the new corporation by virtue of the amalgamation. ...

CRA indicated that having claimed the s. 20(1)(ww) deduction would not preclude X from subsequently claiming the s. 20(1)(j) deduction when the loan was repaid – and indicated that this appeared to be the right policy result. ...

CRA indicated that, pursuant to Reg. 100(4)(a)- which deems an employee, who is not required to report for work at any establishment of the employer, to report for work at the establishment from which the employee’s salary and wages are paid – Mr. ...

CRA stated: Where a provincial government sponsors a program that is designed to have employers provide sick leave payments directly to employees, it is our view that the amount of the payment received by the employee would be included in their employment income under subsection 5(1) …. ...

After noting that government assistance not included in income under s. 9(1) may be includible under s. 12(1)(x), CRA stated: Since the SLRP amounts received by an employer are likely received in the course of earning income from a business, they should be included in the employer’s income in accordance with subsection 9(1) …. ...