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This Proof of Income can be viewed and printed by a taxpayer using the "My Account for Individuals" option …. … [W]ith respect to capital cost allowance that may have been claimed by a taxpayer in prior years, this information could possibly be included in the Proof of Income mentioned above. ...

. … [W]here a property is a capital property, in the absence of plans to proceed with the development of a subdivision, making application to the relevant authority for approval of a plan to subdivide would not, in and by itself, cause the property to be considered as being converted to inventory. Where this is the case, the entire amount of a forfeited deposit would be considered capital in nature …. … [If] a conversion of the land from a capital property to a trading property has taken place … [t]he taxpayer would have a notional capital gain on the date of conversion which would not be considered to give rise to taxable capital gains until the year in which the lots were actually sold. ...

16 December 2019 Internal T.I. 2019-0816101I7- Loans from LTD Partnerships to LTD Partner-- summary under Paragraph 96(2.2)(c) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(2.2)- Paragraph 96(2.2)(c) validity of loan by Ontario LP to limited partner turns on Ontario law When asked whether loans by an Ontario limited partnerships to limited partners would be treated as a loan for purposes of s. 96(2.2)(c), the Directorate indicated that: The reference in s. 96(2.2)(c) to an “amount owing” by a partner to a partnership does not deem partner debts to be valid, but instead merely “suggests that the legislator believed that at least in certain jurisdictions, there could be a debtor and creditor relationship between a limited partner (debtor) and a limited partnership (creditor)” – for instance s. 60(1) of the Partnership Act (B.C.) ... Rye / Klein line of cases): It is well established at common law that a man cannot contract with himself and that a partner cannot contract with a partnership of which he is a member. ... Act providing: “A limited partner may loan money to and transact other business with the limited partnership ….”) – but indicated that the doubts expressed in 2016-0637341E5 as to whether it was possible under the civil law for a limited partnership to make loans to a limited partner were not meant to apply to Ontario limited partnerships. ...

The Directorate concluded: [W]here the installation of such equipment is provided for in the plans and specifications for the construction of a building and the installation is carried out at various stages of the building's construction … it would be difficult to conclude, for this type of contract, that the Taxpayer is not a subcontractor engaged in the construction of a building since those activities are part of the building's construction process. On the other hand … the manufacture and installation of kitchen equipment in buildings already constructed or inside various means of transportation do not constitute activities relating to the construction of a building …. … [T]he Taxpayer may avail itself of the progress method set out in Interpretation Bulletin IT-92R2, provided that title to the construction vests in the Taxpayer's client or in the owner of the building as the work progresses and, furthermore, that the manufacture and installation of the particular equipment are provided for in the plans and specifications for the construction of a building. ...

Consequently, in a situation where a corporation can demonstrate that life insurance proceeds that were paid directly to a financial institution have reduced its debt to the financial institution, the life insurance proceeds will be considered as "received" by that corporation for the purpose of applying subparagraph (d)(ii) of the definition of CDA …. In addition, comments in paragraph 6 of … IT-430R3 … will be modified …. ...

25 February 2002 Internal T.I. 2001-0114167 F- DOMMAGES- DISCRIMINATION-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) awards by human rights tribunals for pain and suffering re wrongful termination often are under $5,000 Regarding what portion a settlement of a claim made under the Canadian Human Rights Act should be treated as compensation for pain and suffering, CCRA indicated that it had not examined the awards pattern of the federal Human Rights Tribunal in this regard, but noted: 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. ...

. … Clause 56(1)(a)(i)(C.1) does not apply to include an amount in income to the extent the amount would not be subject to income taxation in the U.S. if the Taxpayer were resident in the U.S. … You have indicated that [the] return of the investment in contract would be excluded from income for U.S. income tax purposes. Based on this…the amount of the Withdrawal would not be included in computing the Taxpayer’s income …. … [T]he same [would apply] if the Withdrawal took place in a year subsequent to the Taxation Year in which the Deemed Distribution took place … [or] if the Taxpayer was a U.S. citizen, rather than a green card holder, who renounced this US citizenship after becoming a tax resident in Canada … [subject to] subparagraph 4(a) of Article XXIV of the Convention …. ...

Does the application of s. 55(2) to the deemed dividend received by each corporation, which generates an addition to its RDTOH account and, therefore, generates a dividend refund to it and associated Part IV tax on the deemed dividend paid by it to the other corporation, engage the exclusion from s. 55(2) for dividends which are subject to Part IV tax – or does the Part IV tax exclusion not apply so that s. 55(2) applies to the full amount of the deemed dividend received by each corporation? ... Furthermore … in … 943963 Ontario Inc. … the parties … and the Court accepted that there was a given amount subject to Part IV tax by the appellant, the dividend recipient, notwithstanding that a part of the deemed dividend…was deemed to not be a dividend received, by virtue of subsection 55(2). ... The application of subsection 55(2) in that case did not engage any circular calculation. … Moreover, the fact of calculating the RDTOH account at the end of a taxation year of each corporation in such a situation…involving cross redemptions and thus cross dividends, entails circular calculations by them of their respective RDTOH, dividend refunds and Part IV tax. ...

With respect to the expression “in any manner whatever’ in subsection 84(2), the Court noted that “ [t]hese far-reaching words are anchored in history as they have always been part of this provision, and they faithfully reflect its anti-avoidance purpose”. ... It should also be noted that the Federal Court of Appeal also resolved the uncertainties arising from certain decisions that taxpayers frequently invoked against the application of subsection 84(2), namely McNichol … Descarries … and Robillard …. ... CRA also indicated that “ Foix did not express an opinion on the Tax Court of Canada's analysis in Geransky ” and implied that Gernasky has been overtaken by the subsequent decisions of the Federal Court of Appeal in MacDonald and Foix, which “clearly ruled that subsection 84(2) should be interpreted broadly.” ...

Rye / Klein line of cases): It is well established at common law that a man cannot contract with himself and that a partner cannot contract with a partnership of which he is a member. ... Act: “A limited partner may loan money to and transact other business with the limited partnership … ” (i.e., s. 12 does not specifically refer to limited partner borrowings). ...