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. … [T]he negative safe income of corporations would reduce the safe income of a holding corporation only to the extent that it can be considered to result in a reduction of the value of the shares of the holding corporation, for example, either because of a guarantee made by the holding corporation, or because of an actual payment for the losses by the holding corporation [citing Brelco]. ...

Amounts paid to the employee for such travel must therefore be included in computing the employee's income … [and] the employee cannot deduct personal travel expenses in computing income from an office or employment. ...

Since the equitable interest of the donee arose at the moment of the creation of the trust, CRA did not construe there to be a gift of substituted property by the GRE – so that s. 118.1(5.1)(b) did not apply. ...

22 June 2020 External T.I. 2020-0848721E5 F- SSUC- Entité déterminée et institution publique-- summary under Subsection 149(1.1) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1.1) example of application of s. 149(1.1) In the course of a general response to a query by a non-profit organization regarding the exclusion from an "eligible entity" for CEWS purposes of a “public institution” as defined in s, 125.7 (including an organization described in any of ss. 149(1)(a) to (d.6),) CRA stated: [S[subsection 149(1.1) … provides that for the purposes of determining the 100% and 90% ownership tests in paragraphs 149(1)(d) to (d.6) of the Act any right to acquire shares or capital of a corporation should be considered as though the right had been exercised. ...

If the RSUs are settled in Year Four, more than three years after the end of the year in which these services were rendered, the paragraph (k) exception would not apply …. ...

Consequently, the client would not qualify for the wage subsidy in respect of the payment made to the staffing company … [Y]ou mentioned that the client has received an offsetting discount for the wage subsidy received by the outsource staffing company. ...

Relaxing CRA's procedures and any administrative policy in that regard would require a thorough review …. ...

The CRA does not intend to adopt an administrative position that would allow a corporation to avoid making an excessive eligible dividend designation in a situation similar to the one described …. ...

CRA also noted that, administratively, it: [a]llows … mitigating the effects of an excessive eligible dividend designation by accepting that the election provided for in subsection 185.1(2) can be made by a corporation at the time of filing its income tax return, without having to wait for a notice of assessment of Part III.1 tax to be issued. ...

In its summary, the Directorate stated: The proposed subject transaction conforms with the CRA's policy to not apply subsection 55(2) of the Act to internal reorganizations within a related group for loss consolidation purposes and recognizing that property retains its character on a rollover transaction between related parties is consistent with the CRA’s position in … 2014-0553731I7 that depreciable property should retain its character on wind-up. ...