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Accordingly … were Canco and Forco A to make the election … in determining Canco’s decline in qualifying revenue based on Forco A’s decline in qualifying revenue, Forco A would not have any qualifying revenue because it earns all of its revenue from persons or partnerships not dealing at arm’s length with it (Forco B). [Thus] … the election in paragraph 125.7(4)(d) would not work. In our view, the election in paragraph 125.7(4)(d) may not be made by a multi-tiered structure or chain of entities that are not dealing with each other at arm’s length. An election under another special rule under subsection 125.7(4) … may, however, be available … to allow an alternate method of calculating qualifying revenue for an eligible entity, such as the election for affiliated eligible entities in paragraph 125.7(4)(b). ...

CCRA responded: [A]n outstanding deposit [which] is an amount recorded on deposit in the depositor's accounts but not yet cashed by the bank or recorded in the depositor's bank account … can only increase the balance in the bank account to which the deposit relates or reduce the related bank overdraft. … [O]utstanding cheques … are not in themselves loans or advances since the remittance of a simple cheque is not a payment. ...

CRA stated: Under clause 53(2)(c)(i)(B) … the ACB of an interest in a partnership must be reduced by … farm losses without regard to section 31. … The ACB of the taxpayer's interest would therefore be reduced by $75,000 even though the taxpayer has an unused restricted farm loss of $57,500. ...

As for the missions covered for the purposes of subclause 110(1)(f)(v)(v)(A)(II), they are provided for in [Reg.] 7500 …. ... Furthermore …, it would appear that the … operations in which the taxpayer participated are missions referred to for the purposes of subclause 110(1)(f)(v)(A)(A)(II). … [T]he question of whether someone is a member of the Canadian Forces must be resolved in light of the relevant provisions of the National Defence Act. ...

. … IT-373R2 describes the steps to be followed in determining the main tax rules that apply in respect of a woodlot. … Paragraph 7 of IT-481 … states that "[i]f a taxpayer acquires land on which there is standing timber (for example, freehold timberlands), such property is a timber limit.” ...

After finding that he was not able to deduct the legal fees incurred by him in negotiations with the tax authorities, the Directorate went on to state: … E9930565, F9809347 and E9608715 … discussed the tax treatment of the debt paid by directors in discharge of their joint and several liability with a corporation … [and concluded] that the debt arising to the directors from their obligation had not been acquired with a view to earning income from a business or property. ...

It stated: To the extent that Aco exercises its purchase option … Aco's cost of the Vehicle pursuant to subsection 49(3) will be the sum … paid in accordance with the exercise price … plus the adjusted cost base of the option, which will be the portion of the consideration paid that is attributable to the acquisition of that option. ...

However, it is [its] longstanding position … that the CRA must … rely on the facts as they exist at the end of the taxation year. … To the extent that, at the end of a particular taxation year in which the DPBNR received a benefit under an RRSP, the beneficial owner was not identified with certainty, the facts as they existed at the end of the particular taxation year did not permit the benefit to be included in computing a taxpayer's income. ...

However, it is [its] longstanding position … that the CRA must … rely on the facts as they exist at the end of the taxation year. … To the extent that, at the end of a particular taxation year in which the DPBNR received a benefit under an RRSP, the beneficial owner was not identified with certainty, the facts as they existed at the end of the particular taxation year did not permit the benefit to be included in computing a taxpayer's income. ...

Generally, we would not expect that the payment of an Offering Assistance Fee by the Issuer to the Promotor of a FTS offering would, in and by itself, cause shares issued under the FTS offering … [under] section 6202.1 … if the Offering Assistance Fee is paid in circumstances where all the parties involved in the FTS offering, namely the Issuer, the Investor, the Promotor and the Liquidity Provider, deal with one another at arm’s length and the amount of the Offering Assistance Fee is equal to the fair market value of the services for which it is paid. … [A]ll of the facts and circumstances surrounding a FTS offering would need to be considered in detail before concluding whether a particular share issued under that FTS offering is a prescribed share …. ...