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However, assuming that the old partnership was not wound up for tax avoidance reasons, CCRA was prepared to instead accept arguments that ss. 34.1(1) and (8) should be interpreted in light of s. 249.1(1), which contemplates the carrying on of a business at the partnership level – so that the business would cease to exist at the time the partnership ceased to exist, with the result that s. 34.1(8) would render s. 34.1(1) inapplicable. ...

…[A]n employee who is in one of the above situations may … receive from the employer a reasonable reimbursement or allowance relating to expenses incurred in connection with transportation between the employee’s ordinary place of residence and the employee’s work location (including parking near that location) without any taxable benefit having to be included ….in computing the employee’s income from an office or employment. ...

Consequently, the condition in clause 6801(a)(iii)(A) … will be satisfied for both arrangements. ...

. … The wording of the Act does not require that the corporation employ more than 5 full-time employees throughout the year, but rather that it employ more than 5 full-time employees in the business throughout the year. ...

18 April 2002 Internal T.I. 2002-0118827 F- DEBENTURES CONVERTIBLES-- summary under Paragraph 20(1)(f) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(f) no s. 20(1)(f)(ii) deduction on conversion of convertible debentures notwithstanding attempt in resolution to fix the issued shares’ stated capital at their market value The corporation, on the conversion by holders of convertible debentures that it had previously issued, passed a resolution stipulating that the stated capital of the shares issued by it on the conversion was equal to the shares’ market value at that time, and took a deduction under s. 20(1)(f)(ii) equal to ¾ of the excess of such market value over the face value of the converted debentures. ...

18 April 2002 Internal T.I. 2002-0118827 F- DEBENTURES CONVERTIBLES-- summary under Subsection 18(9.1) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(9.1) straight-line or present value method may be used in amortizing premium, and must relate to interest Regarding the potential application of s. 18(9.1) to a premium paid on the early cash redemption of convertible debentures, the Directorate indicated: “if part of the penalty relates to something other than interest, such as debt administration costs, it would not be deductible pursuant to subsection 18(9.1)” – although that did not appear to be the case here regarding s. 18(9.1) covering the amount of a penalty or bonus to the extent that it does not exceed the amount of the total interest that would otherwise have been payable but for the reduction or repayment, the “word ‘value’ in subsection 18(9.1) may therefore be interpreted as meaning the total value and not the present value of future interest payable.” ...

. … Computer software that is downloaded does not meet the characteristics of shrink-wrapped software. ...

. … [T]he expenses incurred by the taxpayer in suing his employer may not be deductible because the taxpayer did not receive compensation for the employment income lost during the suspension period. ...

20 August 2002 External T.I. 2002-0145225 F- Contingent Right to Acquire Shares-- summary under Paragraph 251(5)(b) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b) s. 251(5)(b) not applied iteratively, where shareholders have a pro rata right to acquire another’s shares, and a contingent right to acquire those shares not taken up in the 1st round Situation 1 The shareholders' agreement between the five equal shareholders of Opco provides an obligation of each to sell its Opco shares equally to the others on the occurrence of specified events of fault such as, theft, bankruptcy a breach of any of the provisions of the agreement – but with provision for any shares not so taken up by one of the other shareholder to be divided equally for purchase by the other acquiring shareholders. ...

Consequently … the hypothecary creditor will not be able to include in the calculation of its capital dividend account the proceeds of a life insurance policy that it has received in payment of the debtor policyholder's debt because such proceeds are received only by the policyholder. ...