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After noting its position in IT-145R that “the execution of orders from bulk stock is not considered a processing activity where the activities involved consist solely of counting or measuring and repackaging” and the position in Tenneco that “the goods must undergo a change in form, appearance or nature” in order for there to be processing, CRA stated: [A]lthough the taxpayer's processing activities have the effect of making … [the] products more marketable, we do not believe that there has been any change in the form, appearance or other characteristics of the products..... ...

26 January 2009 Internal T.I. 2008-0303901I7 F- Allocation raisonnable et coûts d'opération-- summary under Subparagraph 6(1)(b)(vii.1) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) Quebec government-mandated travel allowances are reasonable including re depreciation – if too low, can make s. 8(1)(h.1) claim A Quebec government employee, who in the course of her employment must travel to visit patients, receives an allowance of $0.43 per kilometre in accordance with the Government of Québec's Treasury Board Directive for travel allowances. ...

However … the filing of a valid election pursuant to subsection 110(1.1) would enable the employee in this situation to claim a deduction under paragraph 110(1)(d) provided that all of the other conditions of this paragraph are met. ...

. … [T]he issuance of the first certificate of competence is an indicator that an apprentice is eligible. ...

The Directorate stated: Prior to the issuance of the Exercise Notices, it is our view that Opco had no obligation to issue shares of its capital stock …. ...

On the issue of whether a subsection 83(2) election is available to a corporation in respect of a dividend that it is deemed to have paid pursuant to paragraph 84.1(1)(b), we are of the view that such an election is available if such a dividend becomes payable by a private corporation to a shareholder who already holds shares of any class of the corporation's capital stock …. ...

CRA responded: The 2006 Federal Budget announced an increase in the scholarship and bursary exemption so that … a student can no longer deduct moving expenses where the student’s income is derived solely from scholarships or fellowships. ...

Given that such fees constitute business profits, the CRA would not grant a foreign tax credit for the 15% withholding tax on them …. ...

Consequently … subsection 115(2) will not apply as condition [s. 115(2)(c)](iii) is not satisfied. ...

. … CRA also indicated that FX gains or losses would be realized on a USD payable for the acquisition of shares as that payable was settled. ...