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The following are deductible under s. 9 if incurred before making a decision to bring the mine into production (otherwise generally Class 41 or 41.2 assets or other depreciable property, or Class 14.1 if the property is not acquired – or CDE under para. ...

Thus, [such] a clause … would not respect this condition since, during the entire period of bankruptcy, the beneficiary would not be entitled to demand payment of the income generated by the trust. ...

17 May 2022 IFA Roundtable Q. 13, 2022-0926381C6- Statistics on MAPs-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 around half of CRA’s recent MAP cases resulted in full relief CRA provided the following statistics on MAPs for the 2020 calendar year: … The average time to complete a negotiable MAP case was 17.83 months; Of the 74 MAP cases closed in 2020, 36 cases (i.e., 48.6%) resulted in full relief from double taxation upon negotiation, 9 cases (i.e., 12.2%) had objections not justified, and 8 cases (i.e., 10.8%) were resolved through unilateral relief. ...

., and stated: [T]here are arguments to support the contention that the building used 65% by ABC Inc. in its manufacturing activities could be a property used or held primarily to earn income from its manufacturing business for the purposes of subparagraph (b)(ii) …. ...

. … [C]rypto-assets, by their very nature, are more difficult to track than traditional assets. ...

Rye / Klein line of cases): It is well established at common law that a man cannot contract with himself and that a partner cannot contract with a partnership of which he is a member. ...

CRA responded: It is … possible for an individual to use both amounts withdrawn from an RRSP under the HBP and amounts withdrawn from an FHSA for the acquisition of the same qualifying home. ...

8 March 2023 External T.I. 2017-0729871E5 F- Déduction supplémentaire prévue au sous-alinéa 110-- summary under Paragraph 1100(1)(c.1) Summary Under Tax Topics- Income Tax Regulations- Regulation 1100- Subsection 1100(1)- Paragraph 1100(1)(c.1) transfer of Class 14.1 property on s 85 rollover basis eliminated the additional 2% CCA under Reg. 1100(1)(c.1)(i) Regarding where a taxpayer acquired Class 14.1 property after 2016 pursuant to a s. 85 rollover, CRA noted that, for taxation years ending before 2017, Reg. 1100(1)(c.1)(i) allowed a claim of additional CCA of 2% on a portion of the undepreciated capital cost of Class 14.1 property at the beginning of January 1, 2017, and stated: Consequently, a taxpayer is not eligible for the additional deduction provided for in subparagraph 1100(1)(c.1)(i) in respect of a property in Class 14.1 of Schedule II where that property is acquired by the taxpayer after December 31, 2016 as a result of a rollover pursuant to section 85 …. ...

13 April 2023 External T.I. 2017-0684341E5 F- Perte au titre d’un placement d’entreprise-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose business does not cease until the prior commitments incurred in the course of the business are fulfilled Regarding when a mooted small business corporation, which had ceased its restaurant operations in 20X1, but sued the franchisor at the same time with that suit being dismissed in 20X6, ceased to carry on its active business, CRA stated: Following [Poulin], we accept … that an amount for damages may be deducted in a year in which a taxpayer no longer carries on business, since the taxpayer is presumed not to have ceased carrying on business for as long as the taxpayer is engaged in carrying through on acts committed to by the taxpayer in the course of the business, even if, at the time the amount is deducted, the taxpayer is no longer transacting and can no longer attend to the taxpayer’s customers. ...

(e) of the “flow-through critical mineral mining expenditure” definition that the required certification by a “qualified engineer or geoscientist” be “completed … no more than 12 months before the time that the agreement is made,” CRA indicated that the prescribed form is in the process of being completed and will be released to the public very shortly, and that it should be attached to one of the existing forms that are already required in connection with a flow-through share offering, such as the T100A. ...