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. … In this case, the facts submitted are clearly insufficient to allow us to conclude whether or not the XXXXXXXXXX office constitutes a fixed place of business for Canco. ...

Consequently … the estate may designate the portion of the property that you occupied as your principal residence since its acquisition. ...

" … [W]here a farmer, makes application for subdivision, then subdivides the farmland and proceeds to develop it and sell lots, it is our general view that the farmland would be considered to have been converted into inventory at the time of making application to the relevant authority for approval of a plan to subdivide the land into lots for sale. ...

A had been actively engaged on a regular, continuous and substantial basis for many years – but Mr. ...

The ruling letter states: The purpose for the transfer by New FA of its FA1 Shares to BCo … occurring at the Transfer Amount as opposed to occurring at their FMV, was not to confer a benefit on a person, but rather to address certain policy concerns of the CRA by restricting BCo’s aggregate ACB of its FA1 Shares to the Transfer Amount. ...

After repeating its position that “personal travel includes travel between the employee's home and ‘regular place of employment’,” and noting that “regular place of employment” was described in T4130 as including “a client's premises when an employee reports there daily for a six month project” and “a client's premises if the employee has to attend biweekly meetings there,” and before noting that it could only make general comments, CRA stated: If the place of business of a client of the firm constitutes a "regular place of employment " for the auditor, the travel between the auditor’s residence and the place of business of that client is considered personal travel and is therefore not considered travel "in the performance of the duties of the employee’s office or employment". ...

4 December 2018 External T.I. 2016-0670851E5- Regular Places of Employment and Personal Travel-- summary under Paragraph 6(1)(b) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b) scope of “regular place of employment" Respecting requested clarification as to when a particular work location is considered a regular place of employment for an employee, CRA stated: [T]ravel between an employee’s home, including a home office, and a regular place of employment (RPE) is generally considered personal travel …. ...

CRA stated that although “the excess of PUC over ACB of the shares of DCco … could imply that the shareholders may have realized a bargain purchase of the tax attributes of the assets of DCco,” however: [S]nce the main concern of paragraphs 55(3)(a) and 55(3)(b) is to allow for a tax-free reorganization, the CRA would not attempt to challenge a reduction of PUC on the shares of DCco that are held by TCco prior to their redemption where the potential gain on the shares of DCco is transferred to the shares of TCco that are held by the shareholders, i.e., where the PUC and ACB of the shares of TCco held by the shareholders are equal to the PUC and ACB respectively of the shares of DCco held by the shareholders at the beginning of the series of transactions. ...

(a)(i) of the definition of “earnings” in Reg. 5907(1) – but that such adjustments were to be added to its earnings of Forco 1 pursuant to Reg. 5907(2)(f). ...

., its earnings as computed in accordance with the Country A income tax law – but that such adjustments were to be added to its earnings pursuant to Reg. 5907(2)(f). ...