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8 October 2013 External T.I. 2011-0428931E5 F - Assurance-invalidité -- summary under Income-Producing Purpose

. … [T]his policy was not acquired with a view to earning income from the business. ...

8 October 2013 External T.I. 2011-0428931E5 F - Assurance-invalidité -- summary under Exempt Receipts/Business

. … [T]his policy was not acquired with a view to earning income from the business. ...

11 June 2015 External T.I. 2014-0522641E5 F - Usufruct -- summary under Subsection 108(7)

See summaries under s. 73(3) and s. 110.6(1) – qualified farm or fishing property. ...

1 May 2014 External T.I. 2013-0494981E5 F - De Jure Control -- summary under Subparagraph 251(2)(b)(i)

. … [T]his approach should be preferred, in any situation similar to that described in Scenario 3, for establishing who has de jure control of a corporation. ...

30 June 2014 Internal T.I. 2013-0508411I7 F - Part IV Tax and the Dividend Refund -- summary under Subparagraph 152(4)(a)(i)

. … [S]ince the necessity to effect the circular calculation…is well known, we believe that a reasonable and prudent person would have effected the circular calculation in order to report (in the income tax return filed) the correct figures to the Minister. ...

20 August 2015 External T.I. 2015-0581681E5 F - Non-resident trust rules -- summary under Connected Contributor

. … After paraphrasing the definitions of "resident contributor," "contributor" and "resident beneficiary" (which latter definition referenced a "connected contributor to the trust,") CRA stated: Under subsection 94(1), a "connected contributor" includes any contributor to the trust at a particular time other than a person all of whose contributions to the trust made at or before the particular time were made at a non-resident time of the person as defined in subsection 94(1). ...

2014 Ruling 2013-0514561R3 - Payment in lieu of continued PHSP coverage -- summary under Paragraph 6(1)(a)

Proposed transactions Former employees (and dependants where relevant) will receive under a CCAA Plan one or more payments out of the available cash pool of Canco on account of their claim for termination of coverage under the Plans in an amount equal to their pro-rata share of the aggregate settlement amount – except that claims under a Life insurance plan will be paid separately. ...

13 September 2012 Internal T.I. 2012-0442671I7 F - Dédommagement pour la perte de bénéfices -- summary under Subparagraph 6(1)(a)(i)

. … Since a portion of the lump sum received in respect of the Medical Plan was received before 2012, that portion does not have to be included in the computation of the Objectors’ income. ...

23 September 2013 Internal T.I. 2012-0471531I7 F - Non-profit organization -- summary under Paragraph 149(1)(l)

" … [A] member of a non-profit organization can make a loan to a NPO without jeopardizing the status of the NPO, even if the member, as a creditor, receives interest on its debt to the extent that the interest rate on its claim is reasonable. ...

21 January 2013 Internal T.I. 2012-0442021I7 F - Assessing 163(2) penalty -- summary under Subparagraph 163(2)(a)(i)

. … If, on the other hand, the CCA relates more to the business as a whole (i.e. related to reported income and undeclared income), we are of the view that it would not be wholly applicable to undeclared income and would not be allowed as a deduction for the purpose of calculating the penalty. ...

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