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CRA responded: Under a "charitable" annuity arrangement … a donor transfers an amount to a trust in consideration for which the donor acquires a right to receive an annuity from the trust. ...

In those circumstances, we doubt that the work of the employees is of a temporary nature and, in our view, the … premium could not be excluded from the employees' income by virtue of subsection 6(6). ...

The Directorate, in noting that “[i]t is possible that the person paying salary or wages is not the employer,” repeated the statement in Mollenhauer “that subsection 153(1) … does not speak of whether persons doing the paying are employers or not,” and went on to find that the Persons likely were employees of Cco, so that the charges from Bco for their salaries likely could be included in the “cost of labour” of Cco under Reg. 5202. ...

17 February 2004 Internal T.I. 2003-0046981I7 F- Paragraphe 98(5) de la Loi-- summary under Subsection 98(5) Summary Under Tax Topics- Income Tax Act- Section 98- Subsection 98(5) s. 98(5) inapplicable on an amalgamation of the members The Directorate essentially repeated the position stated shortly thereafter in 2003-0050041E5 F, namely: [S]ubsection 98(5) is not applicable … where the members' interests are sold simultaneously to a corporation, since the corporation was not a member of the partnership immediately before the partnership ceased to exist. ...

To take advantage of this election, you have to complete Form T2075 …. ...

In finding that this amending agreement did not have retroactive effect, so that Monsieur could not amend his prior returns to claim the s. 118(1)(b) deduction for the other child (as was previously prohibited pursuant to s. 118(5) by virtue of him having paid support for that child), the Directorate stated: …. ...

. … [W]here after taking leave an employee retires, we are of the view that this will not generally affect the salary deferral arrangement where this was not otherwise provided for. ...

It is, however, a real and enforceable debt and therefore a true obligation …. ...

After indicating that, assuming that s. 55(4) did not apply, the s. 55(3)(a) exception applied, CRA noted: [T]his Directorate has previously taken the position that subsection 55(4) does not apply where it is shown that a parent retained de jure control of a corporation newly-formed by one of the parent’s children primarily for the purpose of protecting the parent's economic interest in the newly-formed corporation, and that none of the primary purposes of the transactions were to cause persons to become related to each other …. ...

If, according to the T4A (P) slip issued by the RRQ, the death benefit was paid to the "heirs …” of the deceased, this amount must be included in the income of the estate in light of subsections 104(1) and 248(1), under which the heirs of a deceased taxpayer are deemed to be the estate of the deceased for the purposes of the Act. ...