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. … 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.... ...

Furthermore …., under civil and common law, a partnership … is simply the relationship that exists between persons or partners who carry on a business in common for profit. ... We refer you to … Klein [which] stated: …[T]he partnership itself does not have the capacity to be indebted. The debt of the partnership is owed by the partners …. ...

23 June 2010 Internal T.I. 2010-0368161I7 F- 84.1-- summary under Paragraph 84.1(2)(b) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(b) s. 84.1(2)(b) inapplicable to individual’s transfer of ½ of Opco to Holdco (owned by 3 unrelated individuals) for note and non-voting pref Three individuals (A, B, and C) each held 1/3 of the shares of Holdco, and Holdco and another individual, D, each held ½ of the shares of Opco. ... [Thereafter] … the Purchaser … is controlled by a group of 4 persons consisting of A, B, C and D (the Final Group). ... Consequently, the deeming provision in paragraph 84.1(2)(b) could not apply …. ...

Y would not constitute "split income" … [as it] is not an amount described in paragraphs 120.4(1)(a) to 120.4(1)(e) of the definition of "split income". There may, however, be abusive situations where the CRA would consider the use of the general anti-avoidance rule …. [f]or example … if it were found that the transactions were put in place to circumvent the application of the TOSI provisions. … Furthermore, it should be noted that the $400,000 allocated and distributed to Child Y by the family trust could, depending on the facts of the situation, constitute "split income" to Child Y …. ...

B … would be deemed to be nil by virtue of paragraph 40(3.6)(a). Consequently, no amount of the Denied Loss could be attributed to Ms. A under subsection 74.2(1) …. By virtue of paragraph 40(3.6)(b), the amount of the Denied Loss … could, however, be added to … the ACB, to Mr. B, of each of the common shares of … Opco that is owned by him immediately following the disposition of such preferred shares of the capital stock of Opco. ...

14 October 2011 Internal T.I. 2011-0410781I7 F- Repas fournis gratuitement-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) benefit from free meals delivered on-site Respecting a proposal that employees would receive a catered meal service during their shifts, CRA stated: [T]o the extent … the provision of free meals … primarily benefits the employees and not primarily their employer, … the value of that benefit should be included in computing the income of those employees. ...

29 September 2020 External T.I. 2018-0757501E5 F- Crédit pour intérêts sur les prêts étudiants-- summary under Section 118.62 Summary Under Tax Topics- Income Tax Act- Section 118.62 capitalization of interest on a novation would constitute its payment – but novated loan would be a new non-student loan A Quebec post-secondary student loan program provided for an initial 12-month “full exemption period” (in which the Quebec government paid the interest charged on the loan by the lender) and a subsequent six-month “partial exemption period” (during which the student borrower was required to pay interest on the loan balance). ... In addressing whether such capitalized interest qualified as being “paid” under a “loan made” under the Quebec financial assistance program so as to generate a credit under s. 118.62, CRA stated: … The mere addition of accrued interest to the principal amount of an original debt is generally not sufficient in itself to constitute a payment of such interest. If … the addition of interest to the principal … qualifies as a novation … the amount of interest will be considered paid when the novation occurs and will be eligible for the credit by virtue of section 118.62, if all the conditions set out in that section are otherwise satisfied. ...

. … [I]n the event of the death of one of the joint tenants, the property will belong solely to the surviving joint tenant. Whether two … joint tenants … of a share in a MIC should be counted as one shareholder or two individual shareholders for purposes of paragraph 130.1(6)(d) of the Act is a mixed question of fact and law …. ...