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. … [T]he term "group … insurance plan”… includes, in particular, accidental death and dismemberment insurance plans. Therefore, if the Insurance Coverage is a group insurance plan, we are of the view that the total amounts paid by the Employer in respect of an employee during a year of Insurance Coverage is to be included in computing the employee's income from an office or employment under paragraph 6(1)(e.1). … [T]hat the Insurance Coverage primarily benefits the Employer … is not relevant for the purposes of paragraph 6(1)(e.1). ...

CCRA stated: [T]he conversion or exchange rights attached to the newly acquired Class A shares … and permitting the exchange of such shares for Class B shares … would technically constitute a "right to acquire" the substituted property …. These conversion or exchange rights would therefore be deemed to be property identical to the Class B shares … previously disposed of by the Taxpayer. Consequently, the loss incurred by the Taxpayer and resulting from the disposition of the Class B shares … would be a "superficial loss" …. ...

CRA responded: Considering that the payments made … constitute royalties … they are therefore subject to paragraph 212(1)(d) without the need to refer to paragraph 212(1)(d)(i). ...

Consequently … [such] payments … are part of a series of periodic payments and do not constitute an eligible amount within the meaning of section 60.01. ...

In finding that the cost of the land could not be bumped under ss. 87(11)(b) and 88(1)(d), CRA noted: … IT-481... [states], " If a taxpayer acquires land on which there is standing timber (for example, freehold timberlands), such property is a timber limit.” and “Unlike land on which is located a property which qualifies for inclusion in one of the classes in Schedule II of the Regulations, land which is acquired as a part of a timber limit is depreciable under Schedule VI of the Regulations and does not exist as a separate property for purposes of the Act.” ...

In finding that the cost of the land could not be bumped under ss. 87(11)(b) and 88(1)(d) because it was depreciable property, CRA noted: … IT-481... [states], " If a taxpayer acquires land on which there is standing timber (for example, freehold timberlands), such property is a timber limit.” and “Unlike land on which is located a property which qualifies for inclusion in one of the classes in Schedule II of the Regulations, land which is acquired as a part of a timber limit is depreciable under Schedule VI of the Regulations and does not exist as a separate property for purposes of the Act.” ...

Before computing her gain under ss. 128.1(4)(b), CRA noted that the cost of her interest was deemed to be nil by s. 107(1.1), and that the ACB of her interest was to be computed under s. 107(1)(a)(ii) and s. 108(1) – cost amount – para. ...

. … It is … not required that the services be rendered to the payer, either the directors of the corporation (the employer) or the administrator of the settlement fund. ...

After quoting from Nassau Walnut to the effect that a late designation was acceptable where the situation “ does not raise the spectre of retroactive tax planning,” the Directorate stated: [I]f the CRA has the ability to reassess the Taxpayer’s Part I income tax return for year-end #1 pursuant to subparagraph 152(4)(b)(iii) with respect to its disposition of the … US shares … the Taxpayer’s late-filed designation request could be considered. ...

Therefore … the Taxpayer would be eligible to claim a foreign tax credit … [whose] amount … would be determined based on the computational rules of section 126.... ...