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. … [E]xpenditures in respect of research in determining economic viability may be considered to be on income account.... ... If so, it is denied current deduction …. … The postponement or cancellation of a project does not alter the nature of an expense incurred in connection with such project. ...

The Directorate stated: # 2007-022925 and # 2004-0107761E5 … stat[ed] that in situations similar to those of Ms. ...

XXIV(2)(a) is expressly “subject to the provisions of the law of Canada regarding the deduction from tax payable in Canada of tax paid in a territory outside Canada,” and stated: [T]his means that a Canadian resident is subject to the limitations on claiming a foreign tax credit found in the Canadian legislation, and more specifically in section 126, including a timing restriction on when a foreign tax credit may be claimed (see … 2015-0601781E5 ….) ... XIII(7) is not available … and the year of the Deemed Disposition … does not occur in the same year [as] … for U.S. income tax purposes … the Trust may not obtain a foreign tax credit in Canada for the U.S. taxes paid in a year subsequent to the year of the Deemed Disposition (assuming the Trust has insufficient income from other sources in the U.S. in the year the U.S. Property is considered by U.S. income tax laws to have been disposed) …. ...

The Directorate stated: [B]ased on the terms of the Payment Agreements … Canco agrees to make advanced payments to NR that are set off or deducted from the amount due by Canco to NR required under the Initial Contract. ... As such, the nature of the payments is different from [those] … in … 2008-29716 …. ... Accordingly … the advance payments made by Canco to NR under the Payment Agreements are subject to the withholding requirements of section 105 …. ...

7 October 2022 APFF Financial Strategies and Instruments Roundtable Q. 2, 2021-0895981C6 F- Don d’une partie d’un intérêt dans une police d’assurance-vie en faveur d’un organisme de bienfaisance enregistré-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 148- Subsection 148(9)- Disposition implementing a life insurance interest sharing strategy may entail the entire policy’s disposition and uncertainties as to what interest is disposed of An individual owning a policy on that individual’s life with coverage of $1 million, a cash surrender value (“CSV”) of $250,000 and an adjusted cost basis ("ACB") of $150,000, donates ½ of the individual’s interest in the policy to a registered charity or, alternatively, only donates ½ of the entitlement to the CSV. ... CRA responded: [T]he donor will wish to ensure that a new policy is not created and that the portion of the policy the individual wishes to donate has been fully assigned in order to qualify for a donation tax credit. … … [I]t would be necessary to determine, i nter alia, whether the gift of a portion of the policy can be made without resulting, for the purposes of the applicable private law, in a disposition of the entire interest in the policy rather than just a portion of it. ...

. … Furthermore … the favourable tax results … are similar … to those available under the employee stock option rules …. even though … the requirements of paragraph 110(d) or (d.1) are not satisfied. ...

Can the minor child be considered, in these Scenarios, to have sole beneficial interest in the amounts payable under the annuity as required by s. 60(l)(ii)(B) as it was proposed to be amended [which stipulated that the annuity be one "under which the taxpayer, or a trust under which the taxpayer is the sole person beneficially interested in amounts payable under the annuity, is the annuitant …"]? CRA responded: February 27, 2004 … Legislative Proposals … indicate … that the child will be able to benefit from the provisions of paragraph 60(l) as long as the child is the only beneficiary of the trust, before the child’s death, who has an interest in the amounts payable under the annuity. Nowhere in the Act is the expression "amounts payable under the annuity" defined. … Pratte J.A. in Bensol Customs Brokers … explain[ed] the scope of the word “under”: "A claim is made under a statute, in my view, when that statute is the law which, assuming the claim to be well founded, would be the source of the plaintiff's right". … Under this analysis, therefore, the annuity must be the source of the beneficiary's right to collect. … [I]t is our view that the annuities described in these Scenarios would be annuities described in clause 60(l)(ii)(B) to the extent that the Legislative Proposals are adopted. ...

. … … In your opinion, it would be appropriate... to divide … the shares into two lots of equal value. ...

. … Subject to certain exceptions under subsection 4(3) … subsection 4(2) … specifically denies the deduction of items in sections 60 to 64 … in determining income from a particular source. Consequently, a deduction allowed under paragraph 60(s) … is not tied to a particular source …. The amount determined under paragraph 3(c) … which forms variable F of the “non-capital loss” definition in subsection 111(8) … will never be negative, and therefore deductions described in Subdivision E of the Act cannot create or increase the amount of a non-capital loss. ...

For the latter amount to be accepted, it must be reasonable in amount, as to which the Directorate stated: Although the maximum amount provided for in paragraph 53(2)(e) … is $20,000, it is possible that, in similar cases, the Tribunal may award only a relatively small amount compared to this maximum. …[W]e have … asked … for information concerning … human rights at the provincial level. We found that … human rights tribunals in several provinces (some of which had a maximum limit for general damages of less than $20,000 and some of which had no maximum limit at all) generally only awarded amounts below the maximum limit for general damages. ...