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Accordingly: With respect to the submitted situation … there was a partial change of use of the portion of the duplex used for another purpose at the time that portion began to be used in its entirety for personal purposes. ...

A scholarship awarded to a student to complete a research project leading to a Ph.D. and other amounts received by the student to cover the student’s maintenance and study expenses while working on their doctoral dissertation would normally qualify as a research grant within the meaning of paragraph 56(1)(o) …. ...

CRA confirmed this result, and also stated: 1- As the Magdalen Islands were a "prescribed zone" for the taxation years 1988 to 1994; 2- If the individual met all the conditions for the application of section 110.7; and 3- Since the Magdalen Islands have been an "intermediate zone" since the 1988 taxation year; the "specified percentage" for deductions for residents of prescribed zones would be: 100% for taxation years between 1988 and 1992; 66 2/3 % for the 1993 taxation year; and 50% for the 1994 and subsequent taxation years. ...

After quoting from the definition of "general-purpose electronic data processing equipment" including the requirement that there be “an internally stored computer program that … can be altered by the user of the equipment,” CRA stated that given that there was “no indication that the user of the property can modify the computer program stored therein,” the device did not appear to qualify. ...

CRA stated: [T]o the extent that Dividend A was a dividend legally distinct from Dividend B and to the extent that Dividend A was designated as an eligible dividend under subsection 89(14), the fact that only one cheque is issued by Opco in respect of the payment of both Dividend A and Dividend B would not prevent Dividend A from qualifying as an "eligible dividend" …. ...

Since a building does not have the same physical characteristics as a parking lot, it is our view that the building … does not satisfy the condition in paragraph 44(5)(a.1) even though both the parking lot and the building generate rental income. ...

. … However, should the CRA accept the contention that a postdoctoral fellow receives a scholarship and can claim the education tax credit, it would still be of the view that the postdoctoral fellow could not claim the scholarship exemption unless the amount so received was sufficiently related to the qualifying educational program for which the education tax credit is claimed. ...

. … [Here] the contribution was not made within the first 60 days of the calendar year. ...

26 July 2010 External T.I. 2010-0364721E5 F- Revenus de bien et d'entreprise-- summary under Subsection 1100(14) Summary Under Tax Topics- Income Tax Regulations- Regulation 1100- Subsection 1100(14) rental property restriction rule applies to business properties as well/"principally" references over 50% of the time After concluding that “the operator of a bed and breakfast, who has a personal residence in which bed and breakfast rooms are rented out on a short-term basis, is generally considered to be carrying on a business” rather than having a source of property income, CRA stated: Whether or not the rental of a building by an individual is a business, the property may be considered a "rental property" for purposes of the CCA restrictions under subsection 1100(11) …. ...

In this case, since there is no exception in subsection 67.1(2) that would allow the Taxpayer to avoid the application of subsection 67.1(1) … expenses incurred by the Taxpayer for food and beverages paid for during restaurant visits should be subject to the restriction in subsection 67.1(1). ...