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After noting that there would be no taxable benefit under s. 6(1)(a) from the employer's payment of the premiums if this arrangement qualified as a group plan described in s. 6(1)(a)(i), CRA went on to note that its general presumption “that an employee shareholder receives benefits or allowances in their capacity as a shareholder if they can significantly influence the policies of the corporation” can be rebutted if “all employees of the corporation are entitled to the benefit” or if all employees are shareholders or related to a shareholder and the benefit “is comparable (in nature and amount) to the benefits … generally offered by corporations of the same size to non-shareholder employees whose services and responsibilities are similar.” ...

. – but further provided that in special justifiable circumstances, reimbursement of the following allowances could be authorized: a) a compensatory allowance for the self-moving of furniture, equal to 50% of the estimate of a moving firm, b) a compensatory allowance for the self-sale of the residence, established at 3% of the sale price, and c) in the event that the employee waived the employee’s right to the reimbursement of moving expenses, a compensatory allowance for additional moving expenses equaling 50% of the following: certain related expenses, real estate agent fees equivalent to 6% of the residence’s municipal evaluation, notary fees of $850 and the amount of a moving company estimate. ...

Consequently, in the example … a trust created for a minor child under the will would be considered a “testamentary trust” under the definition in subsection 108(1), assuming that paragraphs (a), (b) and (c) of that definition do not apply. ...

If the facts show that it is only the time of payment that is not precisely established, but that there is no uncertainty as to the payment of the amount … it could then be a future obligation to pay and not a contingent obligation. ...

. … [N]o partner should be allocated an amount of income greater than the income realized by the partnership. ...

However, before concluding that “a snowmobile is … not a motor vehicle since it is not designed or equipped for use on public roads,” it stated: The first expression used, “designed or adapted” should, in our view, be used not in the sense of “capacity” but rather in the sense of “having or being organized for a specific use.” ...

However, as the unanticipated fugitive emissions occur within Bco’s pipeline transportation network, Aco may be able to avail itself of the relief provided in subsections 211.92(6) and (7) … because such emissions would likely be due to extraordinary circumstances outside of the control of Aco. ...

However, as the unanticipated fugitive emissions occurred within Bco’s pipeline transportation network, “Aco may be able to avail itself of the relief provided in subsections 211.92(6) and (7) … because such emissions would likely be due to extraordinary circumstances outside of the control of Aco.” ...

. … When the employer completes Part 9 of the form, it should be noted that the employer does not have to ascertain in person the time that the employee will devote to work at home: the employer must simply state whether or not the employer has obliged the employee to rent an office or to use part of the employer’s home for work purposes. ...

On December 31, 2016, Opco had accumulated $100,000 in after-tax profits and safe income, As there were 200 outstanding AA and X shares, the X class shares had a redemption value on January 1, 2017 of $50,100 (($100,000 x 100/200) + $100 of PUC) On January 1, 2017, Opco paid a dividend of $50,000 to Holdco. ... After noting the Robertson rule that “income will be attributable to a particular class of shares in the same ratio in which each class would be entitled if all earnings of the corporation, but not share capital, were to be distributed,” CRA stated: [G]iven that…the Class X and AA shares were entitled to an equal share of Opco’s profits following the issuance of the Class X shares and that the value of the shares of each class would increase due to this share of profits, … the safe income earned or realized annually following the issuance of the Class X Shares could be proportionately allocated based on the number of shares of each class. ...