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CRA responded: An “interest” in the well or accumulation … requires that the payer must have a right to take production from the well or accumulation. ... Of course, the conditions in paragraph (d) of the [CRP] definition … must be met …. ...

. … [S]ubsection 13(3) of the Copyright Act … states that, unless otherwise provided by contract, copyright in a work created in the course of employment is the property of the employer and not of the author. That being said … F 2002-0149781R3 [found] that a right to royalties from SOCAN constituted "eligible property" …. ...

After noting that “under … clause 120.4(1.1)(d)(i)(B) … an amount derived directly or indirectly from a business includes an amount that arises in connection with the ownership or disposition of an interest in the shares of … the corporation that carries on the business, that is, Opco,” CRA indicated that in Year X4, that the specified individual would not be eligible for the excluded share exception respecting a dividend from Investco since, for the last taxation year of Investco, it derived, directly or indirectly, income from a related business in respect of the specified individual by receiving dividends from Opco and also by realizing a capital gain on the Opco share sale (and similarly, in Year X3, dividends were received by Investco in its previous year from the related business). ...

. … IT-226R states … that a gift of a capital interest in a trust is made when the transfer of the property to the trust has been completed and the equitable interest in the trust has vested in the qualified done … [which occurs] where, among other conditions, the size of the qualified donee's interest can be ascertained and it is clear that the qualified donee will eventually receive full ownership of the transferred property. ...

21 February 2023 CPAC Roundtable Q. 12, 2022-0947201C6- TOSI- Excluded Business-- summary under Paragraph 120.4(1.1)(a) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1.1)- Paragraph 120.4(1.1)(a) CRA is prepared to ignore reasonable absences for injury, illness, or birth in applying the actively-engaged TOSI test Regarding the requirement in s. 120.4(1) – “excluded business” – that a specified individual be actively engaged on a regular, continuous, and substantial basis in the activities of the business in either the taxation year, or any five taxation years of the specified individual, s. 120.4(1.1)(a) deems an individual to be so engaged in a taxation year if the individual works in the business at least an average of 20 hours per week during the portion of the year in which the business operates. When asked regarding the impact on this test if the employment is interrupted by injury, illness or the birth or adoption of a child, CRA stated: [T]he 2018 Explanatory Notes support a practical approach …. ...

2018 Ruling 2017-0738041R3- XXXXXXXXXX-- summary under Subsection 104(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(1) a foreign collective investment vehicle is fiscally transparent rather than a unit trust Fund The Fund constitutes a collective investment vehicle that is not a body corporate, a partnership or a limited partnership, under which the Unitholders by contractual arrangements (set out in a deed) between a manager and a depositary, beneficially own the underlying property as tenants in common – with their Units representing proportionate interests in the Fund. ... Subfund The Deed states: “Any reference in this Deed to Units being issued “in respect of” a Sub-fund or “relating” to a Sub-fund shall be construed as a reference to Units which give the holder of them co-ownership of that part of the … Property comprising the Sub-fund in question and the entitlement … to exchange co-ownership of that part of the … Property for that part of the … Property comprising any other Sub-fund.” ...

In response to queries as to the treatment of the free housing provided during the period that the individual was pastor, and of that for the several months following when another individual had been retained as pastor before the individual moved out, as well as to the tax treatment of voluntary contributions from members and as to the availability of the clergy residence deduction, CRA stated: 2009-0350821E5 … deals with a situation similar to yours and … seems to answer your questions …. ...

Thus … the hospitalization expenses … may be eligible medical expenses if the hospital in Country A is a public hospital or a private licensed hospital and the fees were paid for medical services. ...

CRA stated: [A]ny amount paid to a retiree by Taxpayerco should be included in computing the retiree’s income under either section 5 or section 6 … [as] the payment … arises necessarily from the retiree’s employment with Taxpayerco. ...

11 February 2011 External T.I. 2010-0386651E5 F- Admissibilité- Frais médicaux-- summary under Paragraph 118.2(2)(a) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(a) preliminary report of genetic counsellor would not qualify In response to a query of the manager of a health care spending account as to whether an expenditure qualified under s. 118.2(2), CRA stated: [A]lthough … it is difficult … to comment on the application of [s. 118.2(2)(a)] with respect to costs related to a preliminary report of a genetic counsellor to establish the risk of breast cancer, we would generally be of the opinion that such costs are not incurred for maintaining health, preventing disease and diagnosing or treating an injury, illness or disability. ...