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. … [E]lement A.1 must be taken into account in calculating the CEC of CCPC for the 2008 to 2012 taxation years. ...

28 March 2013 External T.I. 2012-0465171E5 F- Frais médicaux- technicien en orthophonie-- summary under Paragraph 118.2(2)(l.9) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(l.9) services of speech therapy technician, who supplemented speech-language pathologist’s services, were ineligible as being unsupervised by a doctor After a physician’s referral, the taxpayer’s child (with a severe and prolonged impairment entitling the taxpayer to a credit for mental or physical impairment under s. 118.3) has been using the services of a speech-language pathologist in the private sector, who can only provide services to the child once every two weeks – so that for the other weeks, the child is seen by a specialized speech therapy technician to whom the child was referred by the speech-language pathologist. ...

. … [O]ne would be the brother of the other for purposes of the Act. ...

Therefore … if the Debt is subsequently repaid to Parentco, Debtor may be entitled to a refund of the Part XIII tax previously assessed. ...

. … At the termination of the usufruct and, thus, of the deemed trust, there is a disposition of property held by the deemed trust in favour of the bare owner. ...

. … Based on the limited description…the digital currency would be held outside of Canada and would not be considered to be used or held exclusively in the course of carrying on an active business. ...

Canco paid Japanese income tax on the capital gain reported on such disposition and also reported a capital gain for Canadian tax purposes – but later determined (with CRA's concurrence) that the fair market value of the shares had been nil. ...

CRA responded: [T]he term "construction" in its ordinary meaning and …[Reg.] 238(1) … are broad enough to include most of the projects that could be qualified as landscaping. ...

. … If the automobile benefit was conferred on Son…in his capacity of employee of the corporation and Son included the value of the benefit in computing his income from employment…no amount would be included in computing income of his father under subsection 15(1)…. ...

. …. If, in the case described, there in fact is an allocation of capital gains of the SEC to its partners, we believe it would be difficult to maintain that they do not retain their character in the hands of the latter, including the Limited Partner. ...