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CRA found that: [T]he Taxpayer’s right to reduce the Interest Debt … falls within the definition of a “right to reduce” in subsection 143.4(1) because it is reasonable to conclude, having regard to all the circumstances, that the right will become exercisable [i.e., that the conditions precedent would be thereafter satisfied]. ...

The TFSA contract requires the maintenance of an asset minimum (described as a “margin call provision … “in order to secure the loan”), i.e., so that the nephew cannot liquidate the TFSA unbeknownst to his uncle. ...

., the determination of whether the hypothetical particular person controls a corporation) for the purposes of paragraph (b) …. ...

CRA indicated: [W]here an employee works at a very great distance from the employer's place of business because of the requirements of the employment and not because of the personal choice made by the employee … the travel made by the employee between the employee’s place of work and the employer's place of business is travel made in the performance of the duties of the employee's office or employment. ...

In applying the surrogatum principle … the amount paid by the employer- to replace an amount that would not have been taxable- should not be taxable either. ...

Even if subsection 75(2) no longer applied, the attribution rules in sections 74.1 and 74.2 would have to be considered …. ...

Paragraph 20 of IT-73R6 … indicates that the CRA considers a business carried on by a corporation as a member of a partnership not to be a SIB if the partnership employs more than five full-time employees, and that, accordingly, the corporation's share of the income from the business can be included in the calculation of its "specified partnership income" ("SPI"). ...

After noting its position in IT-145R that “the execution of orders from bulk stock is not considered a processing activity where the activities involved consist solely of counting or measuring and repackaging” and the position in Tenneco that “the goods must undergo a change in form, appearance or nature” in order for there to be processing, CRA stated: [A]lthough the taxpayer's processing activities have the effect of making … [the] products more marketable, we do not believe that there has been any change in the form, appearance or other characteristics of the products..... ...

26 January 2009 Internal T.I. 2008-0303901I7 F- Allocation raisonnable et coûts d'opération-- summary under Subparagraph 6(1)(b)(vii.1) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) Quebec government-mandated travel allowances are reasonable including re depreciation – if too low, can make s. 8(1)(h.1) claim A Quebec government employee, who in the course of her employment must travel to visit patients, receives an allowance of $0.43 per kilometre in accordance with the Government of Québec's Treasury Board Directive for travel allowances. ...

However … the filing of a valid election pursuant to subsection 110(1.1) would enable the employee in this situation to claim a deduction under paragraph 110(1)(d) provided that all of the other conditions of this paragraph are met. ...