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. … … [W]here the transaction is not commercially reasonable, the borrowed money does not meet the test in paragraph 20(1)(c) of being used for the purpose of earning income. ...

Repairs or Running Expense expenditure on Canadian film production can be current expense if it is only of short-term use Is whether an expenditure on a "Canadian film or video production” ("CFVP") is a current expense, or a capital expenditure on depreciable property, determined in accordance with the criteria set out in 9722707, which states: Generally, the cost of preparing a tape will normally be considered a current expenditure where the tape is only of short-term use, either because it is merely of current topical interest or because it is intended to be shown only once (…) In these latter situations, the material is normally retained on the tape for record purposes only. ... CRA responded: The criteria set out in that paragraph may still be used …. … In addition … a likelihood of a particular production generating revenues other than those provided for in the original broadcast contract, for example, from the sale of DVDs, the awarding of contracts for broadcasting on the Internet, on specialty channels or in territories not covered by the original broadcast contract, can also be taken into consideration in determining whether the costs related to a production should be considered as capital expenditures in respect of depreciable property. … [W]here the broadcast contract covers a period of several years, under which the broadcaster has the right to broadcast the production several times during that period, this would be an argument to support that the costs associated with the production provide a lasting benefit to the producer. ...

In addition, the CRA generally considers that the Purpose Tests [in ss. 55(2.1)(b)(i) and (ii)] could apply to a dividend paid by an operating company to its corporate shareholder in order to dispose of surplus assets for the purpose of the purification and subsequent sale of [its] shares … 2017-0724021C6 …. … [T]he payment of the Dividend and the Sale are part of the same series …. ... Consequently, subsection 55(2) should likely apply …. ...

CRA responded: Based on … subsection 96(1), the CRA's practice is to treat a partnership as a person and a taxpayer when calculating income at the partnership level under Division B of Part I …. … [A] partnership would generally be considered a "taxpayer" for the purposes of subsections 51(1), 85.1(1) and 86(1) and would therefore be entitled to rely on the rules contained therein …. ...

CRA responded: Based on … subsection 96(1), the CRA's practice is to treat a partnership as a person and a taxpayer when calculating income at the partnership level under Division B of Part I …. … [A] partnership would generally be considered a "taxpayer" for the purposes of subsections 51(1), 85.1(1) and 86(1) and would therefore be entitled to rely on the rules contained therein …. ...

Nevertheless, since it is clearly established in the collective agreement that travel expenses are to be paid by the employer, it is not possible to invoke the concept of tacit or implicit agreement as invoked in … Moore … and … Betz... [which] determined that travel was implicitly required as part of the taxpayers' employment in order to properly perform their duties and obtain a favourable performance appraisal. … ...

In this regard we cite … MDS Health … and … Haro Pacific …. ...

However, a foreign educational institution that is [so] listed … will be recognized as a "post-secondary educational institution" …. However, it is the RESP promoter's responsibility to ensure that educational assistance payments under the plan are made in accordance with the conditions of registration set out in paragraph 146.1(2)(g.1). … … If a promoter wishes to obtain confirmation that a foreign educational institution is recognized for the purposes of section 146.1, it may make a request to the following address: …. ...

CRA stated: If … the survivor's benefit received by the individual's estate is one of the components of the long-term disability insurance plan, it is likely that this benefit would qualify as a "death benefit" …. … A benefit received as a consequence of the death of a person qualifies as a death benefit if it can reasonably be regarded as being paid in recognition of services rendered by that person in connection with an office or employment. ...

17 April 2003 Internal T.I. 2003-0181507 F- PRET SANS INTERET-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) accessing the exceptional circumstances test requires demonstrating “a sufficient connection between the interest-free loan and an indirect source of the person's income” After surveying the jurisprudence on the exceptional circumstances test, the Directorate stated: Interest deductibility in other situations involving interest-free loans by a person to a corporation of which the person is not a shareholder may be justified on the particular facts of the case, as in Canadian Helicopters … and … Byram … to the extent that the person can show that there is a sufficient connection between the interest-free loan and an indirect source of the person's income. ...