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. … [T]he Canadian citizen to whom you refer in your request will be able to benefit from the exemption for the gain realized on the disposition of the residence located in France to the extent that a person with French nationality whose situation in fact and in law is identical to the individual’s own could benefit from it. ...

After paraphrasing the s. 20(1)(r) wording, indicating that, to be deductible, “the contributions must relate to services rendered to that corporation as an employee” and discussing the s. 67 limitation, CRA stated: [T]hat subsection does not … restrict the contributions necessary to fund an RCA. ...

A, who held ½ of the common shares of Opco having a PUC and ACB of $100, a safe income on hand of $699,900 and a fair market value of $1,000,000, transferred his common shares to a new corporation (“Holdco”) in consideration for common shares of Holdco, with the s. 85(1) agreed amount being $300,000, thereby realizing a $299,900 capital gain for which he claimed the capital gains deduction. ...

. … Please note that the definition of a retirement compensation arrangement does not require that the contributions become the property of the person to whom they are made or that a trust be created. ...

. … While there may be arguments that the costs of obtaining a health insurance card and opening a bank account are personal costs that do not benefit the employer, there are also arguments for considering these costs as part of the reasonable costs of the president's move to Canada. ...

Furthermore, the Taxpayer was to return to the Employer's employ for a period at least as long as the number of years she had pursued her doctoral studies and on the date of her submission … she was still employed by the Employer. ...

. … [T]he custodian of an RCA who holds a letter of credit would not be able to make the election under subsection 207.5(2). ...

For example [there would be such] benefit … if one of the conditions of remaining a capital beneficiary was to continue to be employed by Opco, so as to render services to Opco.... ...

Regarding the meaning of "or the taxpayer’s principal place of residence is maintained for use as the residence of that other individual,” the Directorate stated: The phrase … refers to specific situations, such as where a taxpayer receives amounts because the taxpayer’s principal place of residence is available to host beneficiaries at any time for various periods. ...

. … [P]aragraph 248(3)(f) essentially restates what subsection 248(3) provided at the time, except that the wording is now different and cannot be interpreted as in the Construction Bérou Inc. case. ...