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Regarding the first assumption, CRA stated: [T]he better position is that [s. 163(1)] does not apply where a taxpayer files T1 income tax returns simultaneously for a number of consecutive taxation years and the taxpayer's income tax returns for the earlier taxation years were filed in accordance with the provisions of the Act …. … [T]he CRA should not apply subsection 163(1) respecting Mr. Y's unreported income under the first scenario …. Regarding the second assumption, CRA stated: [I]f the failure to report an amount to be included in Mr. ...

Rather … this type of benefit is included in computing a taxpayer's income under paragraph 56(1)(a). Indeed … subparagraph 56(1)(a)(vii) … provides that a benefit paid under [such] Act … will be included in computing a taxpayer's income …. ...

This principle has been invoked … [in] Burnco Industries … Wawang Forest … and Newfoundland Light …. ...

After noting that the Finance Technical Notes indicated that this “election is meant to allow the shareholders of a foreign affiliate to access their capital first as measured by the adjusted cost base … of the shares,” CRA stated: Even though the preamble of paragraph 5901(2)(b) … does not specify to whom the “whole dividend” … is paid … based on a contextual and purposive analysis … the “whole dividend” … is a reference to a dividend that would cause a consequential ACB adjustment to the shares of the foreign affiliate on which it is paid, if a Regulation 5901(2)(b) election could be made in respect of that dividend. ...

. … [W]hen the time is right, Aco realizes its investments and profits from them. … [T]hese facts alone demonstrate that generally Aco's share acquisitions would be made in the ordinary course of business of the corporation it operates. … … Gco was only formed to be used in the process of disposing of Aco's interest (via XXXXXXXXXX) in the capital stock of Bco. ... To the extent that, based on such an analysis, it was demonstrated that Aco's investment in Bco was not exceptional in relation to its other investments, we would be of the view that the shares of the capital stock of Gco would have been acquired in the ordinary course of the business carried on by Aco and/or XXXXXXXXXX and that subsection 112(2.1) would apply …. ...

A, Holdco A and Trust A sell ½. ½ and ¼, respectively, of their shares of Corporation A on a s. 85(1) rollover basis in exchange for similar-attribute shares of Newco. ...

For example, in subsection 74.1(1), Parliament wrote "...the income or loss … of that person for a taxation year from the property or from property substituted therefor.....". … Furthermore … the definition of substituted property in subsection 248(5) … [only] applies to provisions of the Act that contain the words "substituted property". ...

Accordingly … the provision of benefit coverage to non-unionized employees, in and of itself, would not disqualify the trust as a HWT. … [T]he provision of benefit coverage to retired employees or non-employees would not disqualify a trust as a HWT where the underlying plan or policy (i.e., a GSAIP, PHSP, or GTLIP) allows for the provision of benefit coverage to such individuals. … [A] GTLIP may only provide benefit coverage to current and former (including retired) employees. … …Folio S2-F1-C1 … clarifies that a trust funded only with contributions made by employees or an employee union would not qualify as a HWT. However … there is no explicit requirement that an employer be legally obligated to make contributions in respect of each plan or policy administered by a HWT. [W]here is it established that retired employees may be provided benefit coverage through a GSAIP, PHSP, or GTLIP, and none of the participating employers have a legal obligation to pay any premiums or contributions in respect of the particular plan or policy, it would appear permissible for a HWT to administer such a plan or policy provided that the trust also administers other employer-funded plans or policies. … A HWT may administer a plan that offers drug and alcohol rehabilitation services, provided the plan qualifies as a PHSP. … [A] plan that otherwise meets all of the conditions in paragraph 3 of … IT-339R2 … is considered a PHSP as long as all of the expenses covered under the plan are medical or hospital expenses (“medical expenses”) or expenses incurred in connection with and within a reasonable time period following a medical expense, and all or substantially all (generally 90% or more) of the premiums paid under the plan relate to the coverage of medical expenses that are eligible for the medical expense tax credit (“METC”). ...

1 May 2020 External T.I. 2020-0846931E5- CEWS- public institution-- summary under Paragraph 149(1)(d.3) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(d.3) functional approach to determining the ownership of the “capital” of a non-share corporation In response to an inquiry on the Crown corporation branch of the definition of a public institution in s. 125.7(1) of the CEWS rules, CRA first paraphrased the rules in ss. 149(1)(d) to (d.6) as well as referring to the deeming rule in s. 149(1.1), and then indicated that, in determining the ownership of the “capital” of a non-share corporation for these purposes, it would consider the following factors: • the identity of members, • the structure of the corporation, • who exercises control over the financing, operation and direction of the corporation, • who has the right to elect or change the board of directors or to reverse its decision, • who can contribute capital and receive a distribution of capital, • details regarding asset distribution on winding-up or dissolution and • whether a person other than her Majesty in right of Canada, a province or a Canadian municipality has any right to acquire any capital of the corporation. ...

30 January 2006 External T.I. 2005-0159331E5- Long term disability lump sum payments-- summary under Paragraph 6(1)(f) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) lump sum in lieu of future benefits under employee disability plan is non-taxable In response to a query as to CRA’s position regarding the taxability of lump sum payments of long-term disability benefits that do not represent arrears, it stated: On the basis of … Tsiaprailis … taxable amounts under paragraph 6(1)(f) … include lump sum settlements that are attributable to disability payments in arrears and accruing to the date of the settlement. However, where an individual receives a lump sum payment in lieu of future benefits that would have been otherwise paid under an employer long-term disability plan, in circumstances such that the payment can reasonably be considered to be proceeds of disposition of an interest in an insurance policy, it is our view that the proceeds are not taxable under paragraph 6(1)(f) of the Act or as a capital gain pursuant to subparagraph 39(1)(a)(iii) …. ...