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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). ...

. … [I]t is the selling party, Corporation A, that paid non-business-income tax to the government of a country other than Canada for the purposes of paragraph 126(1)(a), which can, therefore, compute a foreign tax credit under subsection 126(1). ...

CRA then indicated that in this type of arrangement (or one where the employee only receives advances during the leave – in which case, it is not within the DSLP rules), the employee is entitled to a s. 8(1)(n) deduction as the advances are “repaid” (i.e., out of reduced pay cheques following the return to work). ...

. … “[I]mmediately” in the phrase “to immediately dispose of the security and pay all or a portion of the proceeds” in subsection 110(2.1)…refers to both the disposition of the security and the payment of the proceeds to the qualified donee. ...

. … The question of whether the assumption by the beneficiary of the debt of the trust constitutes consideration for the acquisition of a beneficial interest in the trust is a question of fact…. ...

. … Where the grantor can change the terms of, or completely revoke the trust during their lifetime, they effectively retain control of the trust assets. ...

.-- summary under Subsection 1102(23) Summary Under Tax Topics- Income Tax Regulations- Regulation 1102- Subsection 1102(23) further work on an addition does not fall into a separate class CRA considered that if there are two separate additions to a pre-2007 non-residential building, an election under Reg. 1101(5b.1) must be made on each separately and each addition will fall into a separate class – whereas if the work on a single addition extends over more than one year (or there is a subsequent second addition to further extend the first addition), the election can be made at the end of the first year with respect to the work done to date (although this might have no immediate impact under the available-for-use rules) and the subsequent work will fall into the same separate deemed new class without any need to make a second election. ...

9 March 2017 External T.I. 2016-0680071E5 F- Règles transitoires- immobilisations admissibles-- summary under Paragraph 13(38)(d) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(38)- Paragraph 13(38)(d) s. 13(38)(d)(iii) election can be available notwithstanding that only a minor pre-2017 ECE was incurred At the 2016 CTF Annual Conference, Q13, CRA indicated that the s. 13(38)(d)(iii) election to maintain the effect of the s. 14(1)(b) inclusion is unavailable where a taxpayer’s only intangible asset was internally-generated goodwill with no cost – so that the taxpayer could not be said to have made or incurred an ECE in respect of the business, thereby ousting the election. ...

16 June 2017 External T.I. 2016-0674541E5- Mineral Certification-- summary under Paragraph (f) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (f) exploring a placer jade deposit did not qualify as CEE The Minister of Natural Resources advised CRA that nephrite (a type of jade) to be extracted from the in-situ deposits on the subject property was an industrial mineral contained in non-bedded deposits – but excluding placer nephrite deposits, which were considered to not qualify as “a mineral deposit in respect of which...the principal mineral extracted is an industrial mineral contained in a non-bedded deposit.” ...

22 May 2009 External T.I. 2009-0311241E5 F- Compensation reçue pour harcèlement psychologique-- summary under Retiring Allowance Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance award to dismissed employee for psychological harassment by the employer was non-taxable The Labour Relations Board found that an employee had not been wrongfully dismissed, so that the individual was not entitled to damages or salary in lieu of notice for the loss of employment – but also confirmed that the employee had been the victim of psychological harassment by the employer during the last months of employment and ordered the employer to pay the employee $30,000 in moral and punitive damages. ...