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CRA first noted: … Consolidated Holding … and … Fawcett …held that there is no distinction to be made between a person acting in his or her personal capacity or as a trustee. ... Thus, where a trust established for one purpose controls one corporation and a second trust established for another purpose controls a second corporation, and the same trustees vote the shares of both corporations held by each trust, we are of the view that the two corporations are generally controlled by the same group of persons. … Applying these principles, CRA concluded: [B]ecause of their role as trustees of each of the trusts, X and Z would form a group of persons that could control each of the corporations involved. ...

In finding that the penalty could qualify as a “child care expense,” the Directorate stated: [T]he expression “expense incurred … for the purpose of providing … for an eligible child … child care services …” is sufficiently flexible to include contract termination fees where such fees were provided for in the initial agreement between an individual and a daycare centre that set out the commitments and obligations of each party. ...

CCRA noted that “[s]everal court cases, including … Benjamin … 54 DTC 357 … have determined that travel expenses incurred by a taxpayer to attend to rental properties are personal expenses of the taxpayer and therefore not deductible pursuant to paragraph 18(1)(h).” ...

CRA stated: "[A]ny amount paid by the taxpayer before the end of the year for …installing a land drainage system” … includes the cost of drainage pipes, whether plastic or other material, and the cost of installing these pipes. ... Nevertheless, when a taxpayer leases farmland that the taxpayer owns to someone else … "income … from a farming business" … means that an amount is deductible under that provision only by a taxpayer who carries on a farming business and not by a taxpayer who earns rental income. ...

. … On the other hand, if the pastor of your church holds an office or employment, he or she will be required to include in computing income … the value of [the] … lodging … [but] may be eligible for the clergy residence deduction by virtue of paragraph 8(1)(c) if he or she satisfies both of the following conditions: [s. 9(1)(c) conditions summarized]. ...

Our view is supported by the … Explanatory Notes …. Therefore … since it has been assumed that Mrs. ...

James … 66 DTC 5241 …. Subsection 164(4.1) … does not … prevent a taxpayer from changing the computation of the taxpayer’s loss carryforward from a previous year … consequent on a favourable decision received by another taxpayer. ...

17 April 2001 External T.I. 2001-0074915 F- Fonds commun de placement- Disposition-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition change in taxable account through which MFT units are held does not entail their disposition Regarding whether there is a disposition when a taxpayer transfers mutual fund units held in a taxable account with one financial institution to taxable account at another financial institution, so that there is a change in the administrator, CCRA stated: To the extent that a change in the administrator of an account in which mutual fund units are held does not entitle the owner of such units to proceeds of disposition of property and does not result in a change in the beneficial ownership of such units … such a change generally does not constitute a … “disposition” …. ...

The Directorate concluded that “ it would be difficult to argue that the distributions made by the trustee which are stated to be capital distributions in the memoranda of decisions … are required to be included in [her] income under subsection 104(13).” Before so concluding, the Directorate stated: [T]he trustee of a discretionary trust can normally choose whether to make a certain payment out of income or out of capital- at least, to the extent of the trust's income and capital. … In this case, [the resident beneficiary] is both an income beneficiary and a capital beneficiary and can receive either income or capital distributions in any taxation year. However, the trustee cannot change the true nature of an income distribution by merely considering it to be a capital distribution. … As stated in … 2000-0043847 … the amount of income to be included in a beneficiary's income under subsection 104(13) is the amount of the trust's income for tax purposes that has been distributed to the beneficiary. ...

The Directorate responded: [T]he CRA … allows a taxpayer who owns two or more rental properties that are located in two or more locations other than the taxpayer's principal residence to deduct reasonable travel expenses incurred in collecting rents, supervising repairs, and managing the property. Generally, we consider that a taxpayer who owns a single rental property is not carrying on a business and, as a result, the taxpayer’s travel expenses are considered personal and therefore not deductible. … Benjamin … 54 DTC 357 … determined that travel expenses incurred by a taxpayer to attend to rental properties are personal expenses of the taxpayer. The CRA does, however, provide relief for a taxpayer's reasonable motor vehicle expenses incurred by the taxpayer to transport tools and materials to a rental property to perform all or part of the repair or maintenance work on the taxpayer’s rental property, provided that the property is located in the taxpayer's home area. … It should be noted that this policy does not provide relief for travel expenses to collect rents if the taxpayer has only one rental property and is not carrying on a business. ...